i I I**-~** , 

# r .---
"Topromote the airfieldandindustrialparkwith fiscally responsible management andprovide a diverse economic base for the GreaterKingmanArea" 

# • ••**~•** July 23, 2014

# ~

Docket Clerk Office ofthe General Counsel US Department ofTransportation Washington, DC 20590 

# .

. 

# -

# ~**~~~---·~-** -i(."·-'·:-.. ·v**-v:.~** .r::**-~,..,C**... ::-- .; ,,='.Jn1 

### lJ :::.:

## s:**:::~** w.. 

# ;;:.;oo ;: '".- -:--1 Petition ofKingman Arizona for a Waiverfrom the 10-EnplanementStatuteDocket-OST-DOT-1996-1899 -J
We ask for consideration ofa waiver of49 U.S.C. 

### §41731 (a) (1) (B). Kingman has been a participant in the EAS program since its inception and the hub designation is always debated. Is Kingman's hub Sky Harbor International Airport (PHX) in Phoenix, due to the ability to enterthe national transportation system and the state government location for doing business, or is itMcCarran International Airport (LAS) in Las Vegas due to the closerproximity, Great Lakes Airlines is nowproviding Kingman with service to both Los Angeles International Airport (LAX) and DenverInternational Airport (DEN), so should one ofthese locations be considered as the primary hub.
Whereas driving miles are considered inthe determination and driving miles are the easiest to understand, it might be logical to state that LAS should be Kingman's hub. However, LAS has always been a destination airport and in recent years connections into the national system have been reduced during daytimehours making convenient connections into the national system· difficult. Southwest Airlines and US Airways have made significant cuts and schedule changes which also adversely affect connections.
The actual driving mile distance to Phoenix is debatable based on any given startingpoint in Kingman as the 175 mile defined distance is close. However, airline connections in PHX are also difficult, but more as a result ofthe physical design ofmultiple terminal structures and ground distances to cross with limited transfer times. This affects olderpassengers and families with small children which is a largerpart ofKingman's traveling public. In orderto capitalize
on transfer schedules, the route schedules flown by Great Lakes Airlines between Kingman-and PHX did not accommodate the business/government traveler, which may notbe in the spirit of the EAS program, but does reduce enplanements. During 2013, Great Lakes Airlines was flying to Los Angeles International Airport (LAX) to maximize connections into the national system. We acknowledge the enplanements generated did.not meetthe goals established by the EAS Program. We also recognize there waS a Federal· Aviation Administrationrule changethat took effect on August 1, 2013 pertaining to the



### Kingman Airport Authority, Inc. • 7000 Flightline Drive • Kingman, AZ 86401 • (928) 757-2134 • FAX (928) 757-9871Docket Clerk Office ofthe General Counsel US Department ofTransportation Waiver Petition, Docket-OST-DOT-1996-1899 Page2

minimum hours ofcommercial time required for pilots that caused cancellations and loss of travelers due to uncertainty offlights.
On January 1, 2014, Great Lakes Airlines initiated service to Kingman with one daily round trip flight .to LAX and one daily round trip flight to Denver International Airport (DEN) which allows the airline to maximize their operations for equipment and maintenance with the qualified pilots still available. This two hub service is the best Kingman has experienced since the early 1980's and it should be allowed to be cultivated.
The EAS Program was born out ofairline deregulation, and intended to maintain the ability to access the national transportation system from rural communities. Technologyhas changed, transportation has changed and hub airports are busy during peak hours to accommodate competitive airline operations. Rural America still needs access to the national airport system, but we can'tcompete in the current market without assistance. We respectfully ask for your waiver in this matter.

·Sincerely,

David French Executive Director
DF/br

CC: KAA Board ofDirectors Kingman City Council Members Mohave County Board ofSupervisors