### An Agetl(Y of Harrison and Marion Counties

20<>0AVIATION WAY 

### BRIDGEPORT, WEST VIRGINIA 26330

(304) 842.3400



## = June 19,2014 Mr. Scott Faulk Transportation Industry Analyst U.S. Department ofTransportation Office ofAviation Analysis EAS& Domestic Analysis Division 1200 NewJerseyAve., SE Washington, DC 20S90 RE: Docket DOT-QST-200S-20736 Dear Scott, t. C.:.: 

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## J> ~9 N CO

The North Central West Virglnia'Reglonal Airport has reviewed the Essential Air Service (EAS)bids of SilverAirways. Boutique Air, City UnkAir and SunAir International. We welcome the interest of Boutique Air, City LinkAir and SunAir In our market and appreciate their bid offers. Regarding Boutique Air, the carrier proposed service in one scenario tojust Pittsburgh for $l.5S million and Ina second scenario to both Pittsburgh and Dulles for $2.3 mllli'on. The proposal isfor slngle,englne service and we decline to accept that proposal atthis time. We appreciate the carrier's Interest in our market. Regarding City UnkAir, the carrier appears to be using third party aircraft operators to provide aircraft for its proposed operations aswell asathird party reservations and distribution system for ticket sales.We believe the carrier should confirm its operating plan and obtain Itsown operating certificate prior to being selected to serve our market, We appreciate the carrier's interest in our market but decline to endorse this proposal. SunAir International hasproposed service to Pittsburgh with 26weekly round trips using B-seat Piper Navajo aircraft. The subsidy requirement Is$2.2 million. This carrier had operational struggles during 2013, which appear to be resolved in

### 2014. The aircraft type hasbaggage limitations, which the carrier isworking on. The carrier fell well short of its forecast passengers in several other EASmarkets. We appreciate the carrier's interest Inour market but for these reasons we decline to endorse this proposal. Furthermore, with the exception ofthe Pittsburgh only proposal of Boutique Air, all other proposals from allthree airlines appear to put Clarksburg at significant riskof exceeding the $200 subsidy per passenger cap in fiscal year 2015, While we have been disappointed with the reliability of SilverAirways in recent months and remain concerned that Silver's network partner United Airlines does not price connection travel competitively in many instances, the SilverAirways bid would appear,to bethe best ofthe four.However, we have two very significant concerns regarding the Silver Airways biddocument. The DOT has recently Issued acall for comments on apolicy shift to strictly enforce the $200 capon maximum subsidy per passenger at airports like Clarksburg, starting with fiscal year 2015. We at Clarksburg must assume that the $200 capwill be enforced inthat fiscal year. Our concern isthat Sliver is,in its bid, asking for $2.3 million in subsidy and calling for 12,1380&0 passengers, or asubsidy of $190 per passenger. The forecast of 12,138 passengers Isan Increase over current trends and, combined with the subsidy Increase, puts Clarksburg dangerously close to the $200 subsidy cap. We will work very hard with the carrier on traffic generation, however, it isImportant that we note to the Department that Silvers cost and traffic forecasts leaves usvery little room for error infiscal year 2015 regarding the $200 cap. Our second concern isdeterioration inour service pattern, which raises$200 cap concerns even more. On page 5 of the Silver proposal it shows one of our eastbound flights to Dulles actually routed via Parkersburg. While we appreciate that Parkersburg isbeing added to the Dulles network inthis proposal we have grave concerns about a one stop routings via that city. Parkersburg is65statute miles due west of Clarksburg. From Parkersburg it is215 statute miles nonstop to Dulles for atotal of 280 miles on aone stop routing. This 280 mile one stop routing compares to ISOmiles nonstop or 169 miles via Morgantown. Clarksburg accepts one stop routings paired with itssister city right up the road. We understand that airline economics can sometimes require logical one stop pairing like that and we have shared Dulles service with Morgantown for many years. A routing via Parkersburg is, however, a 187% routing circuity! compared to 112%via Morgantown. We have aresponsibility to make sure we support our local airline and stay under the $200 cap. Silver Airways has aresponsibility to offer our market reasonable flight routings. We struggle to seeaone stop routing via Parkersburg, at 187%of nonstop, asreasonable and believe It may have anegative Impact on traffic. We note these two concerns regarding the Silver Airways service proposal in advance offiscal year 2015 and a probable enforcement of the $200 subsidy cap. We will do everything we can to comply with enforcement of such acap. We note to the OepartmentthatSilver's proposal leaves us little $200 cap room for economic downturn or renewed carrier operational issuesor renewed issues between Silverand itspartner United Airlines. Having said that and made our concerns clear, we endorse the proposal of Silver Airways to continue to provide essential airservice at Clarksburg. Asalways, we appreciate the Department considering our opinions and taking them Into account in the decision process Inthis matter.

Best regards,

RonWatson President Benedum Airport Authority