# CITYOF MERCED

Merced Regional Airport Telephone 209/385-6873
May 1, 2013

Susan l. Kurland Assistant SecretaryforAviation and InternationalAffairs U.S. Department ofTransportation 400 Seventh Street, SW Washington, DC 20590 Fax 209/388-8994

RE: DOT2006-6-10, DOCKET OST-1998-3521 C) Show Cause Response for Essential Air Service (EAS) Program; Merced, California

DearAssistant 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 of2012 (Public Law No. 112.95), Merced did not meetthe 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 issuefor Merced. From 2000 till2008 (Great Lakes Airlines started service in September2008) Merced never averaged less than 10 enplanements peryear using a number ofdifferent carriers. From 2002till 2008 Merced actually averaged over 24 enplanements per day. In the year priorto the FAA Modernization and Reform Act of2012, Great Lakes Airlines averaged over 11 enplanements per day.

There are a couple of reasons Merced did not meetthe minimum criteria in 2012. In no specific order or priority:

1. From July 2012through September2013, Great Lakes Airlines made eleven (11) scheduling changes. Three (3) ofthese changes were "departure/arrival" time changes, eight (8) ofthese changes were eitherto 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 orderto work around "signature" airlines and their priority/control overterminal gates and baggage handler employees. Buildingcustomer 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 lakesAirlines scheduled 709 departures and 707 arrivals. Ofthese, sixty (60) departures and sixty-four (64) arrivals were cancelled. Additionally, Eighty-five (85) departures and two hundred three (203) arrivals did not meetthe "on-time" criteria (+5 minutesfor departures and +16 minutesfor arrival). A vast majority ofthese "lates" were in excess of90 minutes. A numberofthese late arrivalswere 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 ourcommunity can easily meet, exceed, and maintain the 10-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 letterstates, Mineta San Jose International Airport is our closest Medium/Large HubAirport. Our community should not be subjected to the 2.5hourdrive into atraffic congested area dueto the reasons stated above

....reasons ourcommunity has absolutely no control over. Therefore, the City of Merced, sponsorof Merced Regional Airport, respectfully asks notto be dropped from the EAS program. Additionally, we askthe DOTto expedite a new EAS contractRFP since ourcurrent contract expires September30, 2014.

Please contact Ron Elliott, Merced Regional Airport Manager ifyou have any questions, concerns, or need additional information.

Josh Pedroza Mayor City of Merced