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 OFGOGEBIC-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. 41731et 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. 41731et 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)waivedbasic 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 Secretaryshallrequire 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, 2010January 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) ScheduledCancelled % Arrivals 2010 Flight Completion and On-time Performance Data of Great Lakes Aviation at Gogebic-Iron County Airport (IWD) MonthScheduledCanceled % 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% 410% 8 21% March 

### 124 94 30 24% 14 47%10 33% 00% 2 7% 4 13% April 

### 121 104 17 14% 7 41% 2 12% 00% 635% 2 12% May 

### 125 104 21 17% 18 86% 0 0% 00% 0 0% 3 14% June 

### 120 112 8 7% 6 75% 0 0% 00% 0 0% 2 25% July 

### 124 110 14 11% 8 57% 2 14% 00% 0 0% 4 29% August 

### 124 87 4 3% 5 125% 2 50% 00% 0 0% 0 0% September 

### 122 98 24 20% 24 100% 0 0% 00% 0 0% 0 0% October November December Total 

### 1100 884 196 18%103 53%36 18% 00%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