November 

### 7, 2014 Mr. Michael FMartin United States Department ofTransportation Office ofAviation 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 WestThird Street NorthPlatte, 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 forthe 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 offerthe potential togenerate the highest numberof enplanements ofall ofthe presented scenarios. History has shown that communities like ours that have upgraded from propellertojetservice have experienced a huge increase in their enplanements ---in most cases doubling, oreven tripling theirannual total. The revenue generated by this substantial enplanement increase would significantly decrease the amount of EAS subsidy needed to renew our EAS contract forthe followingtwo-year period. Shifting to ERJ service would make atremendous difference in attracting the flying public and restoring confidence in ourair service. Jet aircarriers are typically more reliable. That, along with the fact that ERJ-145's are faster, have aflight 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---- somethingthat will go a long way towards bringing back all those frequentflyers who have given up on ourcurrent air service. ADI has expressed its willingness to workwith 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 ofcompany leadership in community events and meetings with key business leaders. They have also pledged asubstantial financial participation in our planned advertizing and marketing campaigns. On our part, we have begun making significant improvements to ourairport terminal building that will accommodate the needs ofa 50-seat ERJ service.Page 2 A reliablejetservice would significantly bolster the economic development prospects forthe greater North Platte area. The City believes that this type ofservice will greatly enhance effortsto attract new business, which in turn would create newjobs. Like any rural community, our ability to retain existing companies, support the growth ofthese entities, and recruit new companies to our business friendly City, depends upon having reliable and efficient airservice. 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 thatADI must complete the process to obtain a DOTfinancial 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 theirfitness certificate application as needed. We are confident thatADI will be successful in developing a passenger market and growing the number ofenplanements through reliable and passenger-friendly service. We firmly believe thatthe waning of public confidence associated with ourserious air service reliability problems can be addressed effectively byADI. 

### BoutiqueAir Their proposal called forfourflights per day using a Pilatus 12 to carry passengers to and from North Platte's FBO and the FBO at DIA, where avan 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 oftime and enter into the AEAS program. Funding forthe program would come from afederal grant. Our community is 

### very leery ofthe 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 forthe grant. Also, according to law, the cost of such agrant cannot exceed the cost ofour current EAS contract which is $1.7 million. Since Via Air's bid exceeds thatamount by$1.8 million, we do not considerthis proposal to be aviable option. 

### GreatlakesAirlines Great Lakes Aviation submitted four proposals for North Platte. The first bid is for$2.8 million in annual subsidy and includesthree daily round trips using a Beechcraft 19000 in a 9-seat configuration. Their annual forecast forthis service is 5,000 enplanements, which is approximately halfthe traffic ata cost to the EAS program ofover$1.1 million more annually than in the previous EAS period. Additionally, this scenario would notgenerate enough boardings to reach FAA's benchmark classification for primary airports of 10,000 enplanements. As you know, should we not meetthatgoal, we would lose out on $1 Million ofAlP funding thatwe desperately need to maintain our operational and safety airport infrastructure.Page3 The second bid uses 30-seat EMB-120 Brasilia aircraft with trafficforecasted at 10,000annual enplanementsfor a subsidy of$1.99 million annually. This scenario is certainly betterfor both the DOT and the communitythan 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 wavierto fly the 19-seat configuration using a Part 135 certificate. It is ouropinion that this option is not realistic. Great Lake's projecttimeline to get regional jets into service is one and a halfto two years down the road, which is unacceptable for ourcommunity. We understand that the airline's unacceptable reliability record stems from crew staffingshortages resulting from more stringent regulatoryATP requirements forfirst officers. It has been ayear and a half now since those requirements came into effect and Great Lakes, forwhatever reasons, is still unableto provide ourcommunitywith any form of reliable service---- as our current Great Lakes pre-cancelation rate of53% illustrates. Itis 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 apparentto us nowthatwould indicate thattheywill be able to do so in the future. As such, we do not consider any oftheir proposals to be qualifying, orviable options. 

### Summary North Platte's current EAS airservice 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 ourfear that our air service may go into permanent decline ifthattrend is allowed to continue.The negative impact ofsuch an event upon our economywould be huge and it is imperative that we avoid such an outcome. We have the opportunity, with ADI, tojoin similar cities in growing ourtraffic dramatically, solidifying ourair service with quality regional jetservice, and moving in the direction of reducing and hopefully eliminating our need for EAS subsidy. We very much appreciate the DepartmentofTransportation'stireless 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