212 Airport Drive 

www.bradfordairport.net 

july 18,2014 

The Honorable Anthony Foxx 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New jersey Avenue, SE 

Washington, DC 20590 

fi.DFllRD 

EGIOD.RL 

RIRPll~"l~ 

Lewis Run, PA 16738 

814·368·5928 EX 10 

. - · .. _': 

RE: Petition of Bradford, PA for a waiver from the 10-enplanement statute, Docket-OST·DOT-2003-14528 

Dear Mr. Foxx: 

Bradford Regional Airport Authority (Authority) understands that on june 24,2014, the Department of Transportation 

issued Order 2014-6-6; Terminating EAS Eligibility and Establishing Waiver Procedures for Bradford Regional Airport 

(BFD). Commercial air service is an important economic generator in our region. The Authority feels strongly that 

continuing Essential Air Service (EAS) is critical to the economic viability of the community. 

The Authority formally requests an Exemption from 49 U.S.C. § 41731 (a )(1) (B) to continue EAS at BFD. The basis for 

this waiver request is that BFD has suffered from a temporary and steady decline in passenger enplanements since 

Gulfstream International Airlines (now Silver Airways) initiated service in late 2008. The decline can be clearly 

attributed to Silver's poor reliability, inferior aircraft, expensive/shrinking hub at Cleveland Hopkins International 

Airport (CLE) and a management culture at Silver that was at best indifferent and at worst negligent in their handling of 

EAS communities nationwide. 

The Secretary has the ability to grant a waiver to an airport 

that has had a "temporary" reduction in passenger numbers 

below the 10 enplanements per service day. Although 

Gulfstream/Silver was in the market for five years, during 

this time, passengers continued to decline due to the reasons 

cited above. As shown in Table 1, BFD was easily above 10 

enplanements per service day in every year until Gulfstream 

took over except for 2007. The 2007 low passenger count 

can be attributed to the de-hubbing of Pittsburgh 

International Airport (PIT) by US Airways. It took some time 

before other airlines at PIT increased service and average 

fares dropped significantly bringing strong air service to the 

PIT airport today. 

During the selection process in 2008, the community and 

Table 1 BFD Passenger Enplanements 

BFD had signiticant concerns regarding Gulfstream's ability to support new service, their lack of experience in EAS 

communities and their lack of experience operating outside of Florida. It became immediately apparent that 

Gulfstream's operation in CLE was not supported the same as their Florida operations, which led to significant delays 

and cancellations, lack of marketing and sales efforts and management indifference. The bankruptcy of Gulfstream and 
U.S. Department of Transportation 

july 18,2014 

Page 2 

change in management team exacerbated the problems, resulting in a signitlcant passenger decline in 2012. BFD made 

numerous attempts to communicate with management at Gulfstream/Silver over the past tlve years, most of which 

were met with more failed promises, if responses were even received. It was abundantly clear that management at 

Gulfstream/Silver treated the CLE area EAS markets as a steady source of income from federal subsidies with little 

concern for actual performance. 

With the management changes following Gulfstream's bankruptcy, 

the new management of Silver Airways created a situation that was 

significantly worse than before, in both performance and 

enplanements. We believe Silver's problems are a systemic problem 

due to the culture and management of Silver Airways, exemplified 

by a review of their current EAS markets. Of the 18 EAS 

communities that Silver served at the beginning of2014, all but six 

have shown passenger declines from 2011 to 2013. Passenger 

enplanements at those 18 markets declined at a combined rate of 

31.1 percent over those two years, with 10 markets having 

passenger declines in excess of 30 percent (Table 2). It is of no 

surprise that many of Silver Airways' communities have been 

eliminated from the program due to the $1,000 passenger cap or 

are threatened to be eliminated by the 10 enplanement rule. 

Per the definition of temporary being "lasting for only a limited 

period of time; not permanent", it is in our view important to not 

only identifY WHY the reduction in enplanements occurred but to 

also have a sufficient plan in which to return enplanements levels back above 10 per service day. 

In 2008, in response to the community's concerns, BFD became an active participant in the Pennsylvania Air Service 

Committee (PASC), which was founded to help promote the commercial service airports within the state of 

Pennsylvania. As passengers at all five EAS markets that Gulfstream operated at in 2009 began to decline precipitously, 

the PASC, Pennsylvania Department of Transportation (PennDOT) and PIT began working together to determine a 

solution. In 2010, a decision was made to pursue a statewide study to determine passenger demand, and the study 

formally began in 2011. This multi-year study was undertaken to quantify passengers in each catchment area and 

forecast potential enplanements if PIT became our connecting hub. More than 30 community meetings were held 

throughout the state including in each EAS community to discuss air service needs and gauge support for this service. 

This study found that reliable service on 9-seat aircraft to PIT, combined with a low-local fare structure can be 

just as successful at PIT as it has been in St Louis for Cape Air and Air Choice One. See Appendix A for a discussion 

of the PIT Connector study. 

The community, Penn DOT and PIT have spent nearly three years and a significant amount of money studying the issues 

with current air service, and have identified a viable solution to improve passenger traffic and allow BFD to fully satisfY 

EAS minimums of not only the 10 enplanement rule, but also the $200 subsidy per passenger rule. There were countless 

meetings, conference calls and correspondences with nearly a dozen airlines around the country to recruit interest in 

creating a low-fare, regional operation in PIT. The community, along with Penn DOT and PIT. were successful in 
U.S. Department of Transportation 

July 18, 2014 

Page 3 

attaining interest from three different airlines. We feel that partnering with Sun Air will enable BFD to increase 

passengers above 10 enplanements within the first year of operations. 

With being close to implementing this multi-year study and plan, we are looking for the US DOT to allow Bradford to 

start service to PIT and grant a waiver in order to allow us to prove that our concept is capable of increasing 

enplanements back to historic levels. Surely there are no other EAS communities in the country that have been a part of 

such a detailed study and have a fully executable plan on which to right the ship and excel with their EAS. In support of 

this project, Penn DOT and PIT have pledged significant funds for marketing and sales efforts in order to ensure air 

service remains at Bradford while we implement service to PIT. 

We respectfully request a waiver to continue our air service for one (1) year and quickly move to award our EAS 

contract to Sun Air so that we can begin to rebuild passengers to demonstrate to the US DOT that our passenger 

reduction truly was "temporary". We look forward to working with you, the airlines, PIT, and the community to fix the 

broken EAS system at BFD. This plan is a practical solution to increase passenger levels to exceed the EAS minimums 

while ensuring access to the National Transportation System. 

If you have any questions, please contact me at (814) 368-5928. 

Sincerely, 

Thomas C. Frungillo, A.A.E 

Cc: U.S. Senator Bob Casey 

PA Governor Tom Corbett 

PA State Representative Martin Causer 

PcnnDOT Secretary Barry Schoch, P.E. 

Bradford Regional Airport Authority 

Bradford Area Alliance 

Marcellus Shale Coalition 

U.S. Congressman Glenn Thompson 

PA State Senator joe Scarnati 

PA State Representative Kathy Rapp 

McKean County Commissioners 

Pittsburgh International Airport 

University of Pittsburgh at Bradford 

Sun Air International 
Appendix A: Discussion of PIT Connector and Midwest EAS Comparisons 

Pennsylvania Regional Air Service Plan 

Starting in 2012, Mead & Hunt was contracted to perform a statewide study to establish a baseline level of demand from 

the 13 commercial service airports in the state of Pen·nsylvania (excluded both Philadelphia International Airport (PHL) 

and P11l and to determine the viability of connecting those airports to PIT. This was the first comprehensive air service 

development study completed in many of the EAS markets, and enabled the communities to have a better feel for what 

their air service demand actually is. As part of the study, representatives from Mead & Hunt performed more than 30 

community meetings around the state, allowing for direct discussions in each community of current air service, as well 

as discussion of the current airline industry trends. 

The study found that there was significant diversion (i.e. 

leakage) to the larger airports in the region. Leakage is not a 

phenomenon only associated with the smallest EAS markets and 

is experienced by most airports around the country. The study 

found that all13 of the commercial service airports in 

Pennsylvania leaked at a minimum of 40 percent of their 

passengers, while the EAS markets leaked as much as 99 percent 

of their passengers to surrounding airports (Table A.l). 

The study found that PHL and PIT were the main diverting 

airports, broken down geographically. For those markets in the 

eastern half of Pennsylvania, their main leakage was to PHL, 

while those in the western half of Pennsylvania predominately 

drove to PIT for their air service. This was true of the EAS 

Table A.1 Domestic and International Retention 

Catchment Retention o/o 

Area Domestic International Total 

I Allentown 38 8 34 

Altoona _::.:'---+---=1 t---';j_-- ~-~Br~a~d7fu~tu~--~~---+----~0~--~--~3~---~ 

......... ::.D.::.UB::.o"'i"-s--l _ __c.-c--l--..,=,1 ___ +--::6::.....--l 

Erie I 31 38 

Lancaster 

Latrobe 

i 

18 

2 ~-1 

2 

15 

State College 63 47 60 

Wilkes Barre/ i 49 14 Scranton I 1.1 ___ 1--·----~ 

Williamsport 5 

44 

10 

Total I 37 14. 

markets in the western half of Pennsylvania as well. Only in the case of BFD was the primary diverting airport Buffalo. 

Even with Buffalo being a drive that is approximately 67 percent closer in drive time, a fair number of passengers chose 

to still drive to PIT to tly (Table A.2). 

Through the leakage study and a comprehensive survey in each community, Mead & Hunt was able to determine that 

the majority of passengers diverted due to reliability, fares and schedules. Although PIT is not a hub as it was in the 

1990s and 2000s, it still offers more than160 daily departures to 36 destinations. The study completed multiple 

forecasting models for service to PIT, involving aircraft from 50-seat regional jets all the way to nine-seat turboprops. 

The study ultimately found that the scenario that would work the best in to day's environment would be a low-fare, 

high frequency service on nine-seat aircraft. 

The primary causes for leakage are the limited number of frequencies and high fares in comparison to the larger nearby 

airports. The study also found that the combination of markets in "tags" or "one-stops" created a major dissatisfaction 

with customers, as well as greatly decreased the reliability of the service, especially during the winter months when 
Appendix A: Discussion of PIT Connector and Midwest EAS Comparisons 

weather in one community frequently impacted the air service to the other community tied with it. What the study also 

found is that the EAS communities currently around Lambert-St. Louis International Airport (STL) are very similar in 

size and proximity to EAS communities in western Pennsylvania. They had poor service that was unreliable, high priced 

and seldom used. Their service was switched to a similar low-fare, high frequency service on a nine-seat aircraft, and 

passenger numbers improved tive to 10 times their most recent levels. It is important to note that communities that 

had historically boarded less than five enplanements per day are now at more than 15 enplanements per day. 

Midwest EAS Community Comparisons 

Although every community is different and it's difficult to tind perfect "proxy" markets for comparison purposes, the 

closest example for BFD and Franklin is the Midwest EAS communities that surround STL. Table A.3 shows the 

population comparisons and distance to either STL or PIT. It is readily apparent that even the smallest market in terms 

of population, BFD, is larger than half of the EAS markets in the STL system. BFD's proximity and population make it 

similar to Burlington, lA. Even the proximity to the secondary diversionary airport (Moline's Quad City International 

Airport for Burlington and Buffalo for Bradford) are similarly approximately 75 miles away). BFD today, however, 

boards almost 70 percent fewer passengers than Burlington, even though they are a similar proximity from the 

diversionary airport AND BFD has 39 percent more people within 25 miles of the airport 

When comparing passengers from 2009 to 2013, the communities in the STL area have experienced growth from157 

percent to nearly 1,200 percent. During that same time period, BFD's enplanements have SHRUNK by 20 percent. 

Due to the success in the partnership between Cape Air or Air Choice One, STL and the local communities, these 

Midwest EAS markets have seen an explosion in growth in passengers over the past five years with a model very similar 

to the one that is being contemplated for BFD. The commitment of PIT and Penn DOT, however, goes beyond what has 

been done in those markets, and will help to further guarantee the success of the new service. There is very little 

doubt, that BFD, as well as Franklin, would see dramatic growth in passengers with a similar /ow-fare, high· 

frequency operation to PIT, easily maintaining more than 10 enplanements per day.