November 7, 2014 

Mr. Michael F Martin 

United States Department of Transportation 

Office of Aviation Analysis 

EAS & Domestic Analysis Division 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Docket DOT-OST-1999-5173 

Dear Mr. Martin, 

?Mayor's Office 

211 West Third Street 

North Platte, Nebraska 69101 

(308) 535-6724 

Fax: (308) 535-6720 

After careful consideration the community of North Platte, Nebraska recommends that the DOT selects 

ADI as our EAS provider for the next two-year contract period. 

Their $4.14 million bid calls for providing two flights per day using 50-seat ERJ-145's. The bid would 

require the higher subsidy, but would offer the potential to generate the highest number of 

enplanements of all of the presented scenarios. History has shown that communities like ours that have 

upgraded from propeller to jet service have experienced a huge increase in their enplanements ---in 

most cases doubling, or even tripling their annual total. The revenue generated by this substantial 

enplanement increase would significantly decrease the amount of EAS subsidy needed to renew our EAS 

contract for the following two-year period. 

Shifting to ERJ service would make a tremendous difference in attracting the flying public and restoring 

confidence in our air service. Jet air carriers are typically more reliable. That, along with the fact that 

ERJ-145's are faster, have a flight attendant and restroom, make the ERJ's very appealing to the flying 

public. Amortizing the operational costs using a 50-seat configuration allows ADI to charge very 

reasonable fares---- something that will go a long way towards bringing back all those frequent flyers 

who have given up on our current air service. 

ADI has expressed its willingness to work with the City to build ties in the community and region. They 

have pledged a commitment to growth in our market place and have confirmed their intention to 

provide personal involvement of company leadership in community events and meetings with key 

business leaders. They have also pledged a substantial financial participation in our planned advertizing 

and marketing campaigns. On our part, we have begun making significant improvements to our airport 

terminal building that will accommodate the needs of a 50-seat ERJ service. 
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A reliable jet service would significantly bolster the economic development prospects for the greater 

North Platte area. The City believes that this type of service will greatly enhance efforts to attract new 

business, which in turn would create new jobs. Like any rural community, our ability to retain existing 

companies, support the growth of these entities, and recruit new companies to our business friendly 

City, depends upon having reliable and efficient air service. 

ADI has no foreseeable flight crew shortages. They have assured us that their pay scale and benefit 

packages are sufficient to recruit and keep qualified pilots. 

We are aware that ADI must complete the process to obtain a DOT financial fitness certificate. They 

have indicated to us recently that this will be completed by the end of next week. In any event, our 

community is prepared to assist ADI with their fitness certificate application as needed. 

We are confident that ADI will be successful in developing a passenger market and growing the number 

of enplanements through reliable and passenger-friendly service. We firmly believe that the waning of 

public confidence associated with our serious air service reliability problems can be addressed 

effectively by ADI. 

Boutique Air 

Their proposal called for four flights per day using a Pilatus 12 to carry passengers to and from North 

Platte's FBO and the FBO at DIA, where a van shuttle would take them to and from the terminal. Our 

EAS service specifications calls for a pressurized multi-engine aircrafC which makes this proposal not a 

viable option. 

Their proposal, which provides two flights per day using a 30-seat EMB-120 Brasilia, would require North 

Platte to leave the EAS program for a specific period of time and enter into the AEAS program. Funding 

for the program would come from a federal grant. Our community is very leery of the issues associated 

with getting back into the EAS program, should we so wish, as well as the uncertainty associated with 

when Congress might get around to releasing funds for the grant. Also, according to law, the cost of 

such a grant cannot exceed the cost of our current EAS contract which is $1.7 million. Since Via Air's bid 

exceeds that amount by $1.8 million, we do not consider this proposal to be a viable option. 

Great lakes Airlines 

Great Lakes Aviation submitted four proposals for North Platte. The first bid is for $2.8 million in annual 

subsidy and includes three daily round trips using a Beechcraft 19000 in a 9-seat configuration. Their 

annual forecast for this service is 5,000 enplanements, which is approximately half the traffic at a cost to 

the EAS program of over $1.1 million more annually than in the previous EAS period. Additionally, this 

scenario would not generate enough boardings to reach FAA's benchmark classification for primary 

airports of 10,000 enplanements. As you know, should we not meet that goal, we would lose out on $1 

Million of AlP funding that we desperately need to maintain our operational and safety airport 

infrastructure. 
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The second bid uses 30-seat EMB-120 Brasilia aircraft with traffic forecasted at 10,000 annual 

enplanements for a subsidy of $1.99 million annually. This scenario is certainly better for both the DOT 

and the community than the 9 seat bid. However, there is great uncertainly as to when Great Lakes 

Airlines will have the crews and equipment available to provide the kind of reliable service that our 

community deserves. 

Great Lakes' third and fourth bids called for using 19-seat B-1990's and 37-seat or larger regional jets. 

Their $2.12 million 19-seat proposal is contingent upon Great Lakes obtaining a DOT wavier to fly the 

19-seat configuration using a Part 135 certificate. It is our opinion that this option is not realistic. Great 

Lake's project timeline to get regional jets into service is one and a half to two years down the road, 

which is unacceptable for our community. 

We understand that the airline's unacceptable reliability record stems from crew staffing shortages 

resulting from more stringent regulatory ATP requirements for first officers. It has been a year and a half 

now since those requirements came into effect and Great Lakes, for whatever reasons, is still unable to 

provide our community with any form of reliable service---- as our current Great Lakes pre-cancelation 

rate of 53% illustrates. 

It is clear to our community that Great Lakes Airlines will be unable to restore adequate air service to 

our community. They have been unable to fulfill their contractual obligations in the past and there is 

nothing apparent to us now that would indicate that they will be able to do so in the future. As such, we 

do not consider any of their proposals to be qualifying, or viable options. 

Summary 

North Platte's current EAS air service has seen serious decline in reliability and on time performance this 

past year and a half. We have no indication when this might improve. In fact, it is our fear that our air 

service may go into permanent decline if that trend is allowed to continue. The negative impact of such 

an event upon our economy would be huge and it is imperative that we avoid such an outcome. 

We have the opportunity, with ADI, to join similar cities in growing our traffic dramatically, solidifying 

our air service with quality regional jet service, and moving in the direction of reducing and hopefully 

eliminating our need for EAS subsidy. 

We very much appreciate the Department ofTransportation's tireless efforts to find the most effective 

EAS solution for North Platte. We look forward to working with you to that end. 

Yours sincerely, 

~~~ Mayor- City of North Platte