CITY OF MERCED 

Merced Regional Airport Telephone 209/385-6873 

May 1, 2013 

Susan l. Kurland 

Assistant Secretary for Aviation and International Affairs 

U.S. Department of Transportation 

400 Seventh Street, SW 

Washington, DC 20590 

Fax 209/388-8994 

RE: DOT 2006-6-10, DOCKET OST-1998-3521 C) 

Show Cause Response for Essential Air Service (EAS) Program; Merced, California 

Dear Assistant Secretary Kurland, 

We have been requested to "show cause" as to why the Department should not terminate EAS 

eligibility to Merced, California. Based on criteria passed by Congress in the FAA Modernization 

and Reform Act of 2012 (Public Law No. 112.95), Merced did not meet the minimum 10-

enplanement per day criterion. In the fiscal year referenced, October 1, 2012 through 

September 30, 2013, Merced averaged 7. 7 enplanements per day. 

Historically, meeting the 1 0-enplanement criteria has not been an issue for Merced. From 2000 

till2008 (Great Lakes Airlines started service in September 2008) Merced never averaged less 

than 10 enplanements per year using a number of different carriers. From 2002 till 2008 

Merced actually averaged over 24 enplanements per day. In the year prior to the FAA 

Modernization and Reform Act of 2012, Great Lakes Airlines averaged over 11 enplanements 

per day. 

There are a couple of reasons Merced did not meet the minimum criteria in 2012. In no specific 

order or priority: 

1. From July 2012 through September 2013, Great Lakes Airlines made eleven (11) 

scheduling changes. Three (3) of these changes were "departure/arrival" time 

changes, eight (8) of these changes were either to drop or add flights on different 

days and times, and one schedule change was to drop Las Vegas as a destination. 

Las Vegas was a destination our community has utilized since EAS began. Not all of 

these scheduling changes were created by Great Lakes Airlines. LAX terminal 

issues, specifically terminal space and baggage handling requirements, necessitated 

time and day changes in order to work around "signature" airlines and their 

priority/control over terminal gates and baggage handler employees. Building 
customer confidence, loyalty, and satisfaction is severely hampered by numerous 

scheduling changes. 

2. During the year in question (FY 2012) Merced Regional Airport averaged 7.7 

enplanements .... Great lakes Airlines scheduled 709 departures and 707 arrivals. 

Of these, sixty (60) departures and sixty-four (64) arrivals were cancelled. 

Additionally, Eighty-five (85) departures and two hundred three (203) arrivals did not 

meet the "on-time" criteria (+5 minutes for departures and +16 minutes for arrival). A 

vast majority of these "lates" were in excess of 90 minutes. A number of these late 

arrivals were created by baggage handling and gate change issues at LAX. 

Regardless, as with reason #1 above, customer confidence, loyalty, and satisfaction 

suffered greatly. Currently, these LAX issues have settled down and operations are 

running smoother. 

Based on Merced's enplanement history we believe our community can easily meet, exceed, 

and maintain the 1 0-enpianement per day criteria. What Merced experienced in FY2012 is 

obviously a temporary set-back based on reasons stated above. Past enplanement history and 

reliable/dependable service has proven this to be the case. As your letter states, Mineta San 

Jose International Airport is our closest Medium/Large Hub Airport. Our community should not 

be subjected to the 2.5hour drive into a traffic congested area due to the reasons stated 

above .... reasons our community has absolutely no control over. Therefore, the City of Merced, 

sponsor of Merced Regional Airport, respectfully asks not to be dropped from the EAS program. 

Additionally, we ask the DOT to expedite a new EAS contract RFP since our current contract 

expires September 30, 2014. 

Please contact Ron Elliott, Merced Regional Airport Manager if you have any questions, 

concerns, or need additional information. 

Josh Pedroza 

Mayor 

City of Merced