BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

Docket DOT-OST-1996-1266 Docket DOT-OST-1996-1266

Docket DOT-OST-1996-1711

PETITION OF GOGEBIC-IRON COUNTY AIRPORT

FOR RECONSIDERATION

Communications with respect to this document should be addressed to:

Duane R. DuRay

Airport Manager

Gogebic-Iron County Airport

E5560 Airport Road

Ironwood, Michigan 49939

Tel: 906.932.3121

Fax: 906.932.4401

iwdairplane@flyfromironwood.com

October 20, 2010

Essential Air Service at

IRONWOOD, MICHIGAN/ASHLAND, WISCONSIN

MANISTEE/LUDINGTON, MICHIGAN

Under 49 U.S.C. 41731 et seq.
1

BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

Docket DOT-OST-1996-1266 Docket DOT-OST-1996-1266

Docket DOT-OST-1996-1711

PETITION OF GOGEBIC-IRON COUNTY AIRPORT

FOR RECONSIDERATION

I have been authorized by the Gogebic-Iron County Airport Board to support an appeal

to reconsider Order 2010-09-26 rejecting the Charter Air Transport, Inc (CAT) in conjunction

with Public Charters, Inc. (P1) proposal to provide air service to both the Gogebic-Iron County

Airport (IWD) and the Manistee County Blacker Airport (MBL). At this time, they are the only

possible bidder who we believe can adequately address the shortcomings of our current EAS

provider, however if other bids are submitted prior to the deadline, we want to reserve our right

to endorse another carrier.

The Board is expressing no opinion concerning the Department of Transportation’s (DOT)

interpretation regarding Scheduled Air Service in the definition of basic essential air service

provided under 49USC, § 41732. The community is requesting clarification from the Secretary if

a waiver from the Basic Essential Air Service (Scheduled Air Transportation) to the option of a

Public Charter Operation under 14 CFR 380 could be considered. We believe the DOT may have

the ability to consider this possibility because of the overwhelming support of both communities

of the proposed service by CAT/P1, past history of waivers the Secretary has granted to other

situations, and the current need of the EAS program to look for viable options to help support

the program as a whole.

Essential Air Service at

IRONWOOD, MICHIGAN/ASHLAND, WISCONSIN

MANISTEE/LUDINGTON, MICHIGAN

Under 49 U.S.C. 41731 et seq.
2

Within the 49 U.S.C. § 41732 and §41733, some communities reserve the right to waive the level

of basic essential air service of at least a 15 passenger aircraft to smaller aircraft if they desire

and they meet certain criteria under §41732.

a) 49 U.S.C. § 41732 (b) (3) (B), allows communities to agree in writing to accept (waive

the entitled size aircraft) a smaller aircraft to provide service to the place.

b) 49 U.S.C. § 41733 (b)(3) communities are entitled to aircraft of at least 15

passengers if the daily average boarding’s at the place in any calendar year from

1976 through 1986 were more than 11 passengers.

49 U.S.C §41732 (b) (5) establishes the minimum standards of the aircraft and crew size.

a) service provided in aircraft with at least 2 engines and using 2 pilots, unless

scheduled air transportation has not been provided to the place in aircraft with at

least 2 engines and using 2 pilots for at least 60 consecutive operating days at any

time since October 31, 1978. (It should be noted that CAT would meet these

requirments.)

49U.S.C §41732 (b) (3) (B) allows a community the right to waive the minimum standard of

aircraft and crew.

a) The affected community agrees with the Secretary in writing to the use of smaller

aircraft to provide service to the place. (It should be noted that CAT would not need

such an agreement.)

Referencing DOT-OST-2006-23932, Joplin, Missouri (JLN) waived basic essential air service

protection through the Secretary for the safeguard of continued air service at the request of

American Eagle. This waiver was accepted to help JLN acquire air carrier service through

American Eagle.
3

a) 49USC Section 41734 Ending, Suspending, and Reducing Basic EAS. (b) Continuation

of service after notice period). If at the end of the notice period under subsection (a)

of this section the Secretary has not found another air carrier to provide basic EAS

to the eligible place, the Secretary shall require the carrier providing notice to

continue to provide basic EAS to the place for an additional thirty day period or until

another carrier begins to provide basic EAS to the place, whichever occurs first.

Subsection (c) continues the Secretary’s requirement to further extend the hold-in

clause for the carrier wanting to suspend service.

In reference to Order 10-6-4 RFP for Iron Moutain/Kingsford, Michigan, Ironwood,

Michigan/Ashland, Wisconsin, Manistee/Lundington, Michigan, and Escanaba, Michigan. The

Ironwood Airport had been requested to send written notice to the DOT informing them of the

Airports knowledge of the current lack of interline agreements between CAT/P1 to other

mainline carriers after the Ironwood community supported the proposal from CAT/P1. I believe

this written acknowledgement to the DOT was the beginning of acceptance of a waiver from the

Basic Essential Air Service.

a) Under 49USC, §41733, Level of Basic Essential Air Service (c) (C) the interline

arrangements that the applicant has made with larger carrier to allow passengers

and cargo of the applicant at the hub airport to be transported by the larger carrier

through one reservation, ticket, and baggage check-in.

Over the life of the past EAS contract while Great Lakes Airlines has been the designated carrier

for Ironwood, the ridership has dropped significantly. Prior to Great Lakes Airlines, Midwest

Connect had provided service to our airport with a flight schedule conducive to our local

travelers. Nearing the end of Midwest Connects service the carrier had changed the schedule to

the current times. These schedule changes were met with airport and public dissatisfaction.

When Great Lakes were awarded the EAS contract in mid 2008 the schedule remained the same

and service reliability declined. The Airport had contacted Great Lakes Airline requesting

schedule change due to the inability of our traveling public to connect to timely flight options in

the designated hub.

1. 2003 IWD enplanements 2272,

2. 2004 IWD enplanements 2816,

3. 2005 IWD enplanements 3288,

4. 2006 IWD enplanements 3348,

5. 2007 IWD enplanements 2995,
4

6. 2008 IWD enplanements 1487,

7. 2009 IWD enplanements 1105,

8. 2010 IWD enplanements to September 681.

§ 41732 (b) (2) flights at reasonable times considering the needs of passengers with connecting

flights at the airport and at prices that are not excessive compared to the generally prevailing

prices of other air carriers for like service between similar places.

§41733 (c) (A) the demonstrated reliability in the applicant in providing scheduled air service.

The Ironwood Airport Board have viewed these areas and overwhelming feel the schedules and

level of reliability sections within the EAS requirements have been overlooked even though they

are a requirement of the EAS program.

Once again we are supporting the appeal by CAT/P1 in the request of clarification for a waiver

from the Basic Essential Air Service (Scheduled Air Transportation) to the option of a Public

Charter Operation under 14 CFR 380.

Attachments Enclosed:

1. Passenger enplanements / deplanements

2. On time and cancellations performance reports

Respectfully submitted,

Duane R. DuRay

Airport Manager

Gogebic-Iron County Airport

E5560 Airport Road

Ironwood, Michigan 49939

October 20, 2010

January 64 20 31% 20 31% 64 19 30% 27 42%

February 56 13 23% 21 38% 56 13 23% 21 38%

March 62 15 24% 38 61% 62 15 24% 41 66%

April 61 9 15% 36 59% 60 8 13% 37 62%

May 63 11 17% 44 70% 62 10 16% 37 60%

June 60 4 7% 36 60% 60 4 7% 39 65%

July 62 7 11% 35 56% 62 7 11% 37 60%

August 62 2 3% 35 56% 62 2 3% 37 60%

September 61 11 18% 33 54% 61 13 21% 34 56%

October

November

December

Total 551 92 17% 298 54% 549 91 17% 310 56%

Notes:

On Time

1. On time arrivals are within 15 minutes of scheduled arrival time.

2. On time departures are within 5 minutes of scheduled departure time.

3. Overflies due to no passengers are not included in the canceled flights column (they are excluded from on time performance)

Scheduled Cancelled %

Arrivals

2010 Flight Completion and On-time Performance Data of Great Lakes Aviation at Gogebic-Iron County Airport (IWD)

Month Scheduled Canceled % On Time %

Departures

%
January 128 89 39 30% 17 44% 10 26% 0% 2 5% 10 26%

February 112 86 39 35% 4 10% 10 26% 0% 4 10% 8 21%

March 124 94 30 24% 14 47% 10 33% 0 0% 2 7% 4 13%

April 121 104 17 14% 7 41% 2 12% 0 0% 6 35% 2 12%

May 125 104 21 17% 18 86% 0 0% 0 0% 0 0% 3 14%

June 120 112 8 7% 6 75% 0 0% 0 0% 0 0% 2 25%

July 124 110 14 11% 8 57% 2 14% 0 0% 0 0% 4 29%

August 124 87 4 3% 5 125% 2 50% 0 0% 0 0% 0 0%

September 122 98 24 20% 24 100% 0 0% 0 0% 0 0% 0 0%

October

November

December

Total 1100 884 196 18% 103 53% 36 18% 0 0% 14 7% 33 17%

Notes:

2. Facilities means failure or inadequate operation of fixed facilities equipment at IWD.

Scheduled Actual Canceled % %

Month

2010 Cancellation Causes for Arrivals and Departures - Great Lakes Aviation

1. Under each cause, show where the causes ocurred, e.g., ORD, etc., if not IWD.

Arrivals and Departures Causes of Cancellations

Mechanical Weather Facilities Crew Unavailable Other

No. % No. % No. % No. No. %
January 280 172 72 62 -14% 303 227 83 64 -23%

February 234 236 60 58 -3% 250 227 68 50 -26%

March 239 198 82 78 -5% 281 204 81 73 -10%

April 257 23 75 78 4% 234 27 54 53 -2%

May 256 0 86 78 -9% 256 0 85 87 2%

June 285 109 114 116 2% 246 74 92 89 -3%

July 161 120 143 127 -11% 210 145 116 110 -5%

August 219 140 115 72 -37% 219 138 125 84 -33%

September 194 92 95 75 -21% 221 121 105 71 -32%

October

November

December

Totals 2125 1090 842 744 -12% 2220 1163 809 681 -16%

GOGEBIC-IRON COUNTY AIRPORT

Enplanements and Deplanements

by Great Lakes Aviation

Deplanements Enplanements

Month

2007 2008 2009 2010 2009 2010

% Change

2010 v 2009

% Change 

2010 v 2009 2007 2008