Order 20 1 3

- 9

- 15

Served: September 27 , 201 3

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

Issued by the Department of Transportation

on the 2 7 th day of September

, 2013

In the Matter of the

SMALL COMMUNITY AIR SERVICE

DEVELOPMENT PROGRAM

under 49 U.S.C. § 41743 et seq. DOCKET DOT

- OST

- 20 1 3

- 0120

ORDER AWARDING GRANTS

Summary

By this O rder, the Department awards 25 grants under the Small Community Air Service

Development Program (Small Community Program) benefitting communities in 2 2 states to

assist with the implement ation of the air service initiatives proposed in their grant applications.

The communities

, the amount of funding requested by the communities , and the rationale for

each award are listed in the Appendix to this Order. Award recipients must affirm the ir grant

aw ard s by entering into grant agreement s with the Department on or before November 15 , 2013

. Award recipients may not seek to be reimbursed funds under the Small Community Program

until they affirm their grant awards.

Background

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (AIR

- 21), P ub

. L. No. 106

- 181 ( April 5, 2002 ) , established a new pilot program, to be administered by the

Department of Transportation, designed to help smaller communities enhance their air service

a nd address issues related to high airfares. 1 AIR

- 21 authorized the Small Community Program

through FY 2003. Vision 100

- Century of Aviation Reauthorization Act (Vision 100), P ub

. L.

No. 108 ( December 12, 2003 ) , amended the program, reauthorized it through FY 2008, and

eliminated the “pilot” status of the program. Appropriations are provided for this program for

award in FY 201 3 pursuant to the FAA Modernization and Reform Act of 2012

, P ub

. L. No.

1 See Orders 2002

- 6

- 14 and 2003

- 9

- 14 for a complete description of the history of the Small Community Program.- 2

-

11 2

- 95 (February 14, 2012 )

. For the 2013 grant awards, t he Department has up to $1 1.5 million

, subject to the availability of funds, to carry out this program.

When selecting applicants to participate in the Small Community Program, the Department is

statutorily required to apply the following eligibility criteria:

1. As of calendar year 1997, the airport serving the community was not larger than a small

hub airport, and had insufficient air carrier service or had unreasonably high air fares ;

2. The airport presents characteristics, such as geographic diversity or unique circumstances

that demonstrate the need for, and feasibility of, the Small Community Program ;

3. No more than 4 communities or consortia of communities, or a combination thereof, from

the same state may be selected to participate in the program in a ny fiscal year;

4. No more than 40 communities or consortia of communities, or a combination thereof, may

be selected to participate in the program in each year for which the funds are appropriated;

5. An applicant may not receive an additional grant to support the same project; 2 and

6. An applicant may not receive an additional grant prior to the completion of its previous

grant. 3

In addition, the law directs the Department to give priority to those communities or consortia of

communities 4 where: ( a ) air fares are higher than the average air fares for all communities; ( b ) a

portion of the cost of the activity contemplated by the community is provided from local, non

airport revenue sources; ( c ) a public

- private partnership has been or will be established to

faci litate air carrier service to the public; ( d ) improved service will bring the material benefits of

scheduled air transportation to a broad section of the traveling public, including businesses,

educational institutions, and other enterprises whose access t o the national air transportation

system is limited; ( e ) the funds will be used in a timely manner ; 5 and ( f ) m ultiple communities

cooperate to submit a regional or multistate application to consolidate air service into one

regional airport

. 6

T he Department is authorized to award grants to communities that seek to provide assistance to:

 An air carrier to subsidize service to and from an underserved airport for a period not to

exceed 3 years;

 An underserved airport to obtain service to and from the underserved airport; and/or

 An underserved airport to implement such other measures to improve air service both in

terms of the cost of such service to consumers and the availability of such service,

including improving air service through marketing and p romotion of air service and

enhanced utilization of airport facilities. 7

2 However, as stated in our Request for Proposals ( Order 201 3

- 6

- 14 ), previous grant recipients could submit grant

proposals and seek funds for new projects. See Order 201 3

- 6

- 14 for a discussion on same projects.

3 49 U.S.C. § 41743(c).

4 A consortium of communities is defined as a single entity. 49 U.S.C. § 41743.

5 49 U.S.C. § 41743(c)(5) (E)

. 6 49 U.S.C. § 41743(c)(5) (F)

. 7 49 U.S.C. § 41743(d).- 3

-

On June 24, 2013 , the Department issued a n Order Soliciting Small Community Grant Proposals

(Solicitation Order) from communities interested in receiving a grant this year, and reque sted

that such proposals be filed no later than Ju ly 26 , 201 3 (Order 20 1 3

- 6

- 14 ). The Solicitation

Order required each a pplicant to submit a completed S tandard F orm 424 and a Summary

Information schedule to www.grants.gov . Communities were requested to provide information

that would help in consideration of their grant requests, including details about their existing air

services, historical services, current service needs and deficiencies, a full descriptio n of the

community’s proposal, plans for implementation, funding requirements, and plans for

monitoring the success of the project, including modifying or discontinuing funding if the project

is not meeting expectations.

Drawing on our experience from p re vious y ears, the Solicitation Order discussed various issues

relating to the grant application process, including the sources of local funding, the consideration

of in

- kind contributio n , the use of grant funds, and the eligibility to participate by past gr ant

recipients and communities now receiving subsidized air service under the Essential Air Service

(EAS) program. The Solicitation Order further emphasized that communities would be expected

to meet the financial

- contribution commitments that they includ e in their proposals.

20 1 3 Grant Applications

In response to the Solicitation Order , we received 5 9 grant applications from communities in 3 3

states

. Collectively, these communities sought more than $ 2 8 million in federal assistance to

support new and ongoing air service development projects. Most of the applications were filed

by individual communities

, with a few filed by consortia of communities. Of the 5 9

applications

, eight (8) applications were from communities with small

- hub airports and five ( 5 )

were from communities now receiving subsidized air service under the Department’s EAS

program. Thirty

- three (33) applications were submitted by communities that received grants in

previous years. As requested , applicants provided information on historical and current air

service and airfare issues facing their communities, the economic benefits of air service,

proposed initiatives to remedy air service or airfare problems, and arguments in support of their

proposals. Nearly all the communities pledged local contributions

– funds collected from local,

state, airport, or in

- kind sources

– to complement their requests for federal assistance.

As in previous years, this year’s applications included propos als for feasibility studies, new or

expanded service initiatives, service upgrades, and assorted combinations thereof. Many

applicants cited both service deficiencies and /or high airfares as problems affecting patronage of

their air services , and they sta ted that passengers often drive to other, more distant airports that

have lower fares or offer a wider range of services to more destinations. Despite these “leakage”

issues, the communities seeking funds believe that demand for improved service at their local

airports can be stimulated with financial assistance.

The large majority of applicants specified the need to attract new and/or additional air services to

their communities. Similar to previous years, a majority of applicants also proposed to

imple ment their projects using revenue guarantees or subsidies, together with a variety of

marketing and promotional initiatives. A critical component of most proposals was funding to

support community

- based marketing and promotional initiatives to stimulate d emand and- 4

-

community awareness of local airport services. These efforts are directed at publicizing not only

the availability of air services, but also the convenience of using the local airport compared to

more congested air service hubs or other larger a irports in the region

.

This year, sev eral applications either did not meet the basic eligibility or criteria for participation

outlined above and were determined ineligible in whole or in part for consideration

. Of these

applications, most were found ine ligible because the applicant sought additional funding for the

same, or essentially the same, project that was funded in a previous grant.

20 1 3 Grant Awards

The Small Community Program is unique in that it encourages and affords communities the

opportunity to develop their own solutions to their air service problems based on their particular

needs and circumstances. By providing communities the opportunity to develop and implement

air service projects tailored to their individual needs, the program aims to maximize the potential

for success in the communities’ endeavors. Since the program’s inception, the Department has

sought to maximize the number of partic ipating communities, promote geographic diversity of

the selections, and support a variety of solutions to the problems identified by applicants in order

to provide a wide range of approaches for dealing with the challenges faced by similarly

- situated

comm unities.

With these considerations in mind, we are selecting 25 grant proposals with the objective of

entering into grant agreements with the communities/consortia identified in the Appe ndix to this

O rder. Award recipients must enter into g rant agreement s with the Department before the

recipients may seek to be reimbursed expenses incurred under their Small Community Program

projects . In addition, grant recipients are subject to all grant conditions and assurances required

by federal law, regulations

, an d executive orders. 8 T he Department’s grant agreements will be

transmitted to the selected communities subsequent to the issuance of this O rder.

The proposals we selected incorporate the purpose of the statute, and provide opportunit ies to

test a variety of approaches to improving small community air service in many regions of the

country. The attached Appendix provides a description of each project , the basis for its

selection, and the amount of funding each community requested

. As an overview :

 Sixteen (16) of the awards are made to communities proposing revenue guarantee and/or

marketing support as means to attract new carriers, restore lost service or capacity, and/or

provide air travelers with access to additional markets. These c ommunities are:

Savannah, G eorgia; Hailey, I daho; Bismarck, N orth Dakota; Del Rio, T exas;

Oxnard/Ventura, C alifornia; Gunnison, C olorado; Idaho Falls, I daho; Fort Wayne,

I ndiana; Springfield, M issouri; Wilmington, N orth C arolina; Stillwater, O klahoma;

McAllen, T exas; Richmond, V irginia; La Crosse, W isconsin; Lincoln, N ebraska; and

Charleston, W est V irginia

.

8 See http://www.dot.gov/policy/aviation

- policy/small

- community

- rural

- air

- service/SCASDP for applicable

conditions and assurances.- 5

-

 The award to Worcester, M assachusetts , provides marketing support for the newly

announced s ervice

.

 The awards to Lawton, O klahoma , and Wenatchee, W ashington

, will provide assistance

for marketing campaigns to support existing service and draw more passengers to the

communities ’ airports

. Additionally, the award to Klamath Falls, O regon , is a marketing

grant for existing air service as well as a passenger education effort to inform passengers

of the airport’s name change.

 The award to Wilkes

- Barre/Scranton, P ennsylvania , will provide start

- up cost offsets and

marketing to attract new air service.

 The award to Sanford, M a ine , allows the community to conduct a public transportation

study to address connection deficiencies to nearby airports.

 Three (3) grant awards at EAS communities

– the Mississippi Consortium, Plattsburgh,

N ew Y ork , and the Pelican Consortium in A laska

– will be used to market current EAS

service

. 9

Most of the selected communities are contributing financial resources to their respective grant

projects. In addition, many communities have pledged in

- kind contributions in f urther support of

their air service initiatives. T he local contributions reflect a commitment that is important to the

potential success of the proposed initiatives. Moreover, nearly all of the communities have

(1) established robust public

- private partnerships to enhance communit y participation and

facilitate access to air services

, and (2) provided a specific plan and timetable for using their

grant funds in a timely manner

.

Air Service Development Zone

The statute directs the Department to designate an airport in one community awarded a grant

under this program as an “Air Service Development Zone” (ASDZ), and to work with the

community or consortium on means to attract business to the area surrounding the airport, to

develop land

- use options for the area, and to provide data, w orking with the Department of

Commerce and other agencies. 49 U.S.C. 41743(h). A current grant recipient

— with a grant

award period extending into FY201 4

— remains active as the ASDZ designee. As a result, the

Department did not solicit applications for selection as an ASDZ designee.

9 We note that grant applicants currently receiving subsidized air service under the EAS Program are precluded

from using SCASDP funds to secure air service by other carriers to additional destinations. As we stated in the

Solicitation Order (Order 201 3

- 6

- 1 4 ), we entertain applications from EAS

- subsidized communities that are directed

toward improving use of the EAS being provided. However, we do not select proposals that would conflict with

long

- standing EAS policies, including financial support through th is program of air services that would compete

with EAS, thus drawing traffic from the already subsidized services and potentially increasing the subsidy

requirements for those services.- 6

-

Grant Agreements

As noted above, the Department will execute grant agreements with each recipient. In the

Solicitation Order , we stated that a community cannot accept a new Small Community Program

grant while it is a party to an existing grant under the program, either as an individual community

or as a member of a consortium. Accordingly, a community still party to an agreeme nt pursuant

to a SCASDP grant awarded in a previous year must terminate its participation in that agreement

before it can accept a 20 1 3 grant award and execute a new implementing agreement with the

Department.

We also stated in the Solicitation Order that communities must establish milestones to monitor

the progress of the proposed projects to determine whether amendments are necessary or whether

the grant agreement should be terminated. As we have done in the past, milestones and progress

reporting requi rements will be included in the grant agreements. Federal funds under this grant

program are disbursed on a reimbursable basis, with the communities expending funds for the

grant project and then seeking reimbursement. Communities will not be reimbursed for funds

expended prior to the date on which the grant agreement is executed. In seeking

reimbursements, grant re cipients must provide invoices or other evidence of the expenditure,

details about the expenditure and how it relates to the grant project, and evidence of payment. In

addition, the legal sponsor is required to certify that each invoice is relevant to the authorized

grant project and has been paid. Communities will be required to comply fully with the terms of

their proposals and the grant a greements.

ACCORDINGLY,

1. We select the communities/consortia listed in the Appendix to receive grant awards under

the Small Community Air Service Development Program as described in this Order ;

2. Grant recipients are subject to all grant conditions and as surances that appear at

http://www.dot.gov/policy/aviation

- policy/small

- community

- rural

- air

service/SCASDP

. In addition, to the extent that th e grant agreement permits expenditure

of the awarded Small Community Program funds in any manner that would not be

permitted for funds received as part of Federal Aviation Administration ’s Airport

Improvement Program (AIP), such permission is strictly limited to the expenditure of the

Small Community Program funds awarded under th e grant agreement. Nothing in th e

grant agreement negates the recipient’s obligations to fully comply with FAA Order

5100

- 38C ;- 7

-

3. Each award recipient must affirm this award by entering into a grant agreement with the

Department on or before November 15 , 2013 . Award recipient s may not seek to be

reimbursed under the Small Community Program until they affirm their grant awards ;

and

4. A copy of this O rder will be served on the legal sponsor for each of the communities

awarded grants.

By:

S USAN L. KURLAND

Assistant Secretary for Aviation

and International Affairs

(SEAL)

An electronic version of this document is available

at http://www.regulations.govState CommunityFederal AmountRequestedProject Descripton Basis for SelectionAKPelicanConsortium$300,000Market for existing EASservice.This application aligns with priority and secondaryselection criteria. The project aligns with the timely use offunds and public-private partnership priority criteria. Thecommunity has a defined timeline and several partners arein place to support the project. The proposed project willincrease awareness for the communities, whose access tothe national air transportation system is limited. It meetsthe secondary criterion of location as the communities aregeographically isolated and unique, attributes that limittheir air service access.CA Oxnard/Ventura $500,000Revenue guaranteewith marketing torestore air service toone of the airport's top10 markets. TargetedLas Vegas, Phoenix, orSan Francisco BayArea.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution and material benefits priority criteria as thecommunity is contributing 16.7% of local funding, whichwould help in efforts to restore air service. Many localbusinesses and universities demonstrated support for theair service project, as did evidence of a growingpopulation. In addition, the project aligns with thesecondary criteria as the community has recentlycompleted a study determining its top ten markets and thecommunity has a letter of support from Allegiant.CO Gunnison $350,000Revenue guaranteewith marketing forsummer service toHouston, Dallas, orPhoenix.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution priority criterion as the community has astrong match of 50%, and the community has 10 percenthigher-than-average air fares. In addition, the projectaligns with the secondary criteria as the community hasletters of support from United and US Airways.2013SCASDPFundedProjectAppendixState CommunityFederal AmountRequestedProject Descripton Basis for SelectionGA Savannah $500,000Revenue guaranteewith marketing supportfor a low-fare carrier.Targeting JetBlueAirways to Boston.This application aligns with several priority and secondaryselection criteria. The project aligns with the higher-thanaverage air fares and local contribution priority criteriabecause the fares at the airport are 14 percent higher thanthe national average, and the community is contributing42.9% towards the project. In addition, the project alignswith the secondary criteria because there is a very strongpublic-private partnership that will be important toensuring the success of the program, and the communityreceived a letter of support from JetBlue.ID Hailey $500,000Revenue guaranteewith marketing tosecure nonstop easternhub connections.Targeting UnitedAirlines to Denver.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution and public-private partnership priority criteriabecause the community is contributing 24.7% towards theproject, and the community has well-established partnersin place to help ensure success. In addition, the projectaligns with the secondary criteria as the community has aletter of support from United.ID Idaho Falls $500,000Revenue guaranteewith marketing for airservice toMinneapolis/St. Paul.This application aligns with several priority and secondaryselection criteria. The project will provide material benefitsunder the priority criteria, as the community lacks eastbound air service. In addition, the community isgeographically isolated, and the community has a letter ofsupport from Delta Air Lines, both of which align with thesecondary criteria.State CommunityFederal AmountRequestedProject Descripton Basis for SelectionIN Fort Wayne $600,000Revenue guarantee andmarketing to supportnew service toPhiladelphia, targetingUS Airways.This application aligns with several priority criteria. Theproject aligns with the local contribution, material benefits,and timely use of funds priority criteria. The communityhas a strong funding match of 70.9%, is targeting EastCoast air service that would materially benefit businesses,and the community provided a clearly-defined timeline andproject plan.MA Worcester $350,000Marketing support fornew JetBlue servicethat starts in November2013.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution, public-private partnership, and materialbenefits priority criteria because the community iscontributing 37.5% towards the project, has an establishedpublic-private partnership with funding from the State andlocal governments, and the community currently does nothave air service. In addition, the project aligns with thesecondary criteria as the community has a letter of supportfrom JetBlue.ME Sanford $33,180Study to address publictransportationdeficiencies to nearbyairports.This application aligns with the material benefits priorityselection criterion because the study will allow thecommunity to better understand its transportationchallenges and deficiencies in relation to nearby airports.MO Springfield $450,000Revenue guaranteewith marketing toestablish new airservice to Charlotte.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution and material benefits priority criteria as thecommunity is contributing 15.1% towards the project, andthe community received many letters of support frombusinesses. In addition, the project aligns with thesecondary criteria as the community has a letter of supportfrom US Airways.State CommunityFederal AmountRequestedProject Descripton Basis for SelectionMSMississippiConsortium$120,000Marketing for existingEAS service on SilverAirways to Atlanta.This application aligns with several priority selectioncriteria. The project aligns with the local contribution andhigher-than-average air fare priority criteria because thecommunities are providing 23.1% towards the project andbecause air fares are 30 percent higher than the nationalaverage. In addition, marketing will assist thesecommunities as they all had a carrier change last year.NC Wilmington $750,000Revenue guaranteewith marketing torestore westboundconnections, targetingAmerican Airlines toChicago O'Hare.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution and public-private partnership priority criteriaas the community is contributing 18.8% towards theproject, and the community demonstrated a strong publicprivate partnership. In addition, the project aligns with thesecondary criterion of participation as the community hasbroad community support for its proposal.ND Bismarck $500,000Revenue guaranteewith marketing forservice to Dallas/FortWorth and/or Chicago.This application aligns with several priority and secondaryselection criteria. The project aligns with the higher-thanaverage air fares, local contribution, and material benefitspriority criteria because the fares at the airport are 14percent higher than the national average and thecommunity is contributing 45.5% local funding towards theproject. In addition, the community has experiencedpopulation growth as a result of the growth in the energyindustry. Therefore, the proposed project would materiallybenefit the traveling public.State CommunityFederal AmountRequestedProject Descripton Basis for SelectionNE Lincoln $750,000Revenue guarantee andmarketing support forservice to Atlanta,targeting Delta.This application aligns with several priority and secondarycriteria. The community has higher-than-average airfaresand it has provided financial support for the project,factors that align with the priority selection criteria. Inaddition, the project aligns with the secondary criteria asDelta provided a letter of support.NY Plattsburgh $200,000Marketing for existingEAS service.This application aligns with with several priority criteria.The project aligns with the local contribution and publicprivate partnership priority criteria because the communityis contributing 20% towards the project, and thecommunity has demonstrated a committed public-privatepartnership.OK Lawton $195,000Marketing of existingair service to increaseenplanements.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution, higher-than-average air fare, and publicprivate partnership priority criteria because the communityis providing 16.2% towards the project, air fares are 20percent higher than the national average, and thecommunity has demonstrated a strong public-privatepartnership. In addition, the project aligns with thesecondary criterion of participation as the community hasbroad support for its proposal.OK Stillwater $447,000Revenue guarantee forfirst service toDallas/Fort Worth.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution and public-private partnership priority criteriaas the local community and State are contributing 88.3%towards the project to establish air service for thecommunity. In addition, the project aligns with theparticipation secondary criterion as the community hasbroad support for its proposal.State CommunityFederal AmountRequestedProject Descripton Basis for SelectionOR Klamath Falls $135,000General airportmarketing to increaseenplanements and toinform passengers ofairport name change.This application aligns with several priority and secondaryselection criteria. The project aligns with the localcontribution and public-private partnership criteria as thecommunity is contributing 12.9% towards the project, and ithas established a strong partnership with participationfrom many public and private entities that have developeda strategic plan. In addition, the project aligns with thesecondary criteria of participation and innovation as thecommunity has broad support for its proposal and itdeveloped an innovative marketing campaign.PAWilkes-Barre/Scranton$575,000Start-up cost offsetsand marketing toattract new air service.This application aligns with several priority and secondarycriteria. The project aligns with the local contribution andhigher-than-average air fare priority criteria because thecommunity is contributing more than 22% towards theproject and its airfares are above the national average. Theproject aligns well with the secondary criteria, as Allegiant,Delta, and US Airways provided letters of support for theproject.TX Del Rio $500,000Revenue guarantee torestore air service.Targeting AmericanEagle to Dallas/FortWorth.This application aligns with several priority and secondaryselection criteria. The local cash contribution of 24.6%would help to restore air service at the community andaligns with the local contribution priority criterion. Thecommunity has established a strong public-privatepartnership with almost 40 members, who committedfunding to the local priority contribution. In addition, theproject aligns with the secondary criteria as the communityhas a letter of support from American Airlines, and thecommunity is geographically isolated.State CommunityFederal AmountRequestedProject Descripton Basis for SelectionTX McAllen $750,000Revenue guaranteewith marketing for nonstop service to Denver.This application aligns with several priority and secondarycriteria. The project aligns with the airfares priorityselection criterion as its airfares are higher than thenational average and one of its targeted carriers is a lowfare carrier. The community is also supporting the projectby contributing more than 10% towards the project cost. Italigns with the secondary criteria because the projectreceived a letter of support from Frontier Airlines.VA Richmond $750,000Revenue guaranteewith marketing to gainwestbound air service,targeting Denver andSalt Lake City.This application aligns with several priority criteria. Theproject aligns with the material benefits and localcontribution priority criteria because the proposed projectwill serve a geographic area currently lacking westboundair service, and the community is contributing 6.7%towards the project. The application is also supported by amajor carrier, aligning with the secondary criteria.WA Wenatchee $200,000Marketing program tobolster enplanementson existing AlaskaHorizon service toSeattle/Tacoma.This application aligns with several priority and secondarycriteria. The project aligns with the local contributionpriority criteria because the community is contributing 20%towards the project. In addition, the project aligns withinnovation and location secondary criteria as thecommunity proposes innovative marketing concepts andthe community is geographically isolated.State CommunityFederal AmountRequestedProject Descripton Basis for SelectionWI La Crosse $750,000Revenue guaranteewith marketing forservice to Dallas/FortWorth.This application aligns with several priority and secondarycriteria. The project aligns with the local contribution,higher-than-average air fares, and material benefits prioritycriteria as the community is contributing more than 15%towards the project, and its airfares are 20 percent abovethe national average. In addition, the community willreceive material benefits by adding a new hub destinationto a geographic area not represented by its current airservice offerings.WV Charleston $700,000Revenue guaranteewith marketing and/or astart-up cost offset fornonstop air service toOrlando.This application aligns with several priority and secondarycriteria. The project aligns with the local contribution andpublic-private partnership priority criteria. The communityis contributing more than 13% towards the project and hasa good public-private partnership. The project aligns withthe secondary criteria as Allegiant provided a letter ofsupport.