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"To promote the airfield and industrial park with 

fiscally responsible management and provide a 

diverse economic base for the Greater Kingman Area" • •• ~• 

July 23, 2014 ~ 

Docket Clerk 

Office of the General Counsel 

US Department of Transportation 

Washington, DC 20590 

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Petition of Kingman Arizona for a Waiver from the 10-Enplanement StatuteDocket-OST-DOT -1996-1899 -J 

We ask for consideration of a waiver of 49 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 enter the national transportation system and the state government location for doing 

business, or is it McCarran International Airport (LAS) in Las Vegas due to the closer proximity, 

Great Lakes Airlines is now providing Kingman with service to both Los Angeles International 

Airport (LAX) and Denver International Airport (DEN), so should one of these locations be 

considered as the primary hub. 

Whereas driving miles are considered in the 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 daytime hours 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 starting point in 

Kingman as the 175 mile defined distance is close. However, airline connections in PHX are 

also difficult, but more as a result of the physical design of multiple terminal structures and 

ground distances to cross with limited transfer times. This affects older passengers and families 

with small children which is a larger part of Kingman's traveling public. In order to 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 not be 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 meet the goals established by the EAS Program. We also recognize there waS a Federal· 

Aviation Administration rule change that took effect on August 1, 2013 pertaining to the 

Kingman Airport Authority, Inc. • 7000 Flightline Drive • Kingman, AZ 86401 • (928) 757-2134 • FAX (928) 757-9871 
Docket Clerk 

Office of the General Counsel 

US Department ofTransportation 

Waiver Petition, Docket-OST-DOT-1996-1899 

Page2 

minimum hours of commercial time required for pilots that caused cancellations and loss of 

travelers due to uncertainty of flights. 

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 of airline deregulation, and intended to maintain the ability to 

access the national transportation system from rural communities. Technology has 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't compete 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 of Directors 

Kingman City Council Members 

Mohave County Board of Supervisors