An Agetl(Y of Harrison and Marion Counties

20<>0 AVIATION WAY

BRIDGEPORT, WEST VIRGINIA 26330

(304) 842.3400

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June 19, 2014

Mr. Scott Faulk

Transportation Industry Analyst

U.S. Department of Transportation

Office of Aviation Analysis

EAS& Domestic Analysis Division

1200 New Jersey Ave., SE

Washington, DC 20S90

RE: Docket DOT-QST-200S-20736

Dear Scott,

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The North Central West Virglnia'Reglonal Airport has reviewed the Essential Air Service (EAS) bids of Silver Airways.

Boutique Air, City Unk Air and Sun Air International.

We welcome the interest of Boutique Air, City Link Air and Sun Air In our market and appreciate their bid offers.

Regarding Boutique Air, the carrier proposed service in one scenario to just Pittsburgh for $l.5S million and In a

second scenario to both Pittsburgh and Dulles for $2.3 mllli'on. The proposal is for slngle,englne service and we

decline to accept that proposal at this time. We appreciate the carrier's Interest in our market.

Regarding City Unk Air, the carrier appears to be using third party aircraft operators to provide aircraft for its

proposed operations as well as a third party reservations and distribution system for ticket sales. We believe the

carrier should confirm its operating plan and obtain Its own 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.

Sun Air International has proposed service to Pittsburgh with 26 weekly 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 has baggage limitations, which the carrier is working on. The carrier fell

well short of its forecast passengers in several other EASmarkets. We appreciate the carrier's interest In our

market but for these reasons we decline to endorse this proposal.

Furthermore, with the exception of the Pittsburgh only proposal of Boutique Air, all other proposals from all three

airlines appear to put Clarksburg at significant risk of exceeding the $200 subsidy per passenger cap in fiscal year

2015,

While we have been disappointed with the reliability of Silver Airways in recent months and remain concerned that

Silver's network partner United Airlines does not price connection travel competitively in many instances, the

Silver Airways bid would appear, to be the best of the four.
However, we have two very significant concerns regarding the Silver Airways bid document. The DOT has recently

Issued a call for comments on a policy shift to strictly enforce the $200 cap on maximum subsidy per passenger at

airports like Clarksburg, starting with fiscal year 2015. We at Clarksburg must assume that the $200 cap will be

enforced in that fiscal year. Our concern is that Sliver is, in its bid, asking for $2.3 million in subsidy and calling for

12,1380&0 passengers, or a subsidy of $190 per passenger. The forecast of 12,138 passengers Is an 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 is Important that we note to the

Department that Silvers cost and traffic forecasts leaves us very little room for error in fiscal year 2015 regarding

the $200 cap.

Our second concern is deterioration in our 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 is being added to the Dulles network in this proposal we have grave concerns about a

one stop routings via that city. Parkersburg is 65 statute miles due west of Clarksburg. From Parkersburg it is 215

statute miles nonstop to Dulles for a total of 280 miles on a one stop routing.

This 280 mile one stop routing compares to ISO miles nonstop or 169 miles via Morgantown. Clarksburg accepts

one stop routings paired with its sister 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 a responsibility to make sure we support our local airline and stay under the $200 cap. Silver Airways has

a responsibility to offer our market reasonable flight routings. We struggle to see a one stop routing via

Parkersburg, at 187% of nonstop, as reasonable and believe It may have a negative Impact on traffic.

We note these two concerns regarding the Silver Airways service proposal in advance of fiscal year 2015 and a

probable enforcement of the $200 subsidy cap. We will do everything we can to comply with enforcement of such

a cap. We note to the OepartmentthatSilver's proposal leaves us little $200 cap room for economic downturn or

renewed carrier operational issues or renewed issues between Silver and its partner United Airlines.

Having said that and made our concerns clear, we endorse the proposal of Silver Airways to continue to provide

essential air service at Clarksburg. As always, we appreciate the Department considering our opinions and taking

them Into account in the decision process In this matter.

Best regards,

Ron Watson

President

Benedum Airport Authority