Raleigh County

===~irport 17G Airport Circle • Room 115

Beaver, WV 25B11-9·P.~

Phone 304.255.0476 • Fax 304.253.2095

June 18, 2014

Mr. Scott Faulk

Transportation Industry Analyst

U.S. Department of Transportation

Office of Aviation Analysis

EAS& Domestic Analysis Division

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Docket DOT-OST-1997-2761

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Dear Faulk,

Raleigh County Memorial Airport (BKW) Beckley, West Virginia has reviewed the Essential Air Service

(EAS) bids to provide Beckley EASthat were submitted on May 27,2014. The Department has requested

our comments regarding the merits of the proposals by Thursday, June 19, 2015. This letter will

constitute the comments of the Airport and City of Beckley.

First, we very much appreciate the interest shown in our market by the two bidding carriers, Boutique

Air and City Link Air. We learned, after the May 27th deadline, that a third carrier is now also interested

in bidding to provide EASservice in our market.

We appreciate that the Department has a difficult task in managing an EAS bid process for twelve cities,

Including two that are subject to 10-enplanement enforcement actions concurrent with this bid cycle.

We have reviewed the bid proposals of both Boutique Air and City Link Air carefully. Our comments

regarding each are below.

Boutique Air- The carrier submitted two pro osals, one for 18 trips per week to Pittsburgh with an

annual subsidy need of $1.78 million and one or six trips per week to Pittsburgh combined with 12 trips

per week to Washington Dulles, with the com ined service requiring $2.4 million in annual subsidy. The

carrier proposes to offer these services with 9 seat PC-12 single engine aircraft or "similarly configured

Beech King Air 200/300 aircraft". The addition of comments regarding twin engine aircraft is new to the

May 27 bid document and not further explain d in that document. The carrier mentioned that services

would be displayed in major GDS systems but he carrier does not appear to have any interline ticket

and bag agreements in place. The carrier curr ntly holds one EAS contract in New Mexico and operates

PC-12 and other Cessna aircraft in Nevada and California.

City Link Air - City Link Air proposes to offer 1 trips per week to Pittsburgh for an annual subsidy need

of $2.2 million dollars. The proposed aircraft is a Beech King Air 200/300 with nine seats. The bid is tied

to a bid for Jamestown, NY service and it is impossible for us to determine the cost, revenue and traffic

projections for our market as the bid sheet is merged and all we can do is guess as to our market
forecast. The carrier does not currently operate any flights nor have any aircraft and proposes to use

third party aircraft under wet lease contract for initial operations until a native operating certificate can

be obtained. The carrier advised us that it would have ticket and bag agreements in place and possibly

code share arrangements with network carriers in place at startup or soon thereafter. We are surprised

that a startup airline with third party reservations and operating aircraft arrangements can gain a

codeshare arrangement with a network or other large airline.

After careful consideration we would like to reject both bids and request that the Department

commence a re-bid process for our market. Our reasons are listed below;

~ Boutique Air had originally indicated service would be with a single engine aircraft. We would

prefer not to accept single engine service at this time. The May 27 bid document contains a

reference to operation of service with Beech King Air equipment but provides no details as to

how or when the carrier would get such equipment or how the carrier would reconcile using the

same cost, revenue and subsidy forecast for two very different types of aircraft. Without more

information we cannot endorse this proposal at this time.

~ City Link Air does not currently have an operating certificate or, as far as we can tell, any inhouse operating capability. The carrier envisions startup with third party reservations and

distribution systems and with wet leased aircraft operations provided by a third party aircraft

operator. Given a lack of in-house operating authority and a lack of in-house infrastructure

commonly associated with airline operations, we cannot endorse this proposal at this time.

We do very much appreciate the interest that both carriers have shown in our market and we urge them

to submit bids in a rebid process once they satisfy the eligibility requirements. We hope that both

carries will, at the time of rebidding and in the comment period thereafter, be able to more fully

demonstrate what their final operating plans are in terms of forecast details, aircraft of use and

distribution arrangements.

We very much appreciate the Department working with us to find the most effective EASsolution for

Beckley. Our air service is very important to us and we want to use this bidding process to find an airline

that we can partner with for long term mutual benefit.

Best regarps

d~l/CJ;4-~

Tom Cochran

Airport Manager