MA'Y -29-2012 09: 59A FROM: HAGERSTOWt·H,JASHINGTCI 2403132281 

Hagerstown Regional Airport 

Richard A. Nenson Field 

18434 Shownlter Road, Suite I 

~ Hagerstown, Maryland 21742·1381 

l.f: Telephone: 240..313-2777 

1<1 FAX: 301-791·2590 .~..tit' 

T0 : 912023667638 F'.l-"3 

~v Denf nnd Hnrd of Henring call7-l-1 for Morylnnd Relay 

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May24, 2012 

Mr. Dennis J. DeVany, Chief -- EAS & Domestic Analysis Division 

O:fficc of Aviation Analysis : . ~ -: ::: :· :· ~ 

- . , . J ~ • ... ... 

United States Department ofTrmlSportation 

1200 New Jersey Avenue, SE 

~, . -:-.:::.:.· -

Washington, DC 20590 

Dear Mr. DeVany: 

We are writing in response to the Esse11tial Air Service (BAS) proposal that was summarized in 

your May 4, 2012 e-mail and recorded in the Federal Document Management System (#25228). 

We also wish to take this opportunity to reiterate our appreciation of the EAS Program, its 

administrators and the funding it provides. In this difficult time, without this financial support, 

our ability to assure access to the National Air Transportation system for the citizens of 

Hatcrstown, Washington County and the surrounding quad-state region through Hagerstown 

Rogional Airport (HGR or the Airport) would be challenged. 

Having reviewed your SUlllirutl)' document, Sun Air Express, LLC's (d/b/a Sun Air) original 

proposal and having conducted a face to face meeting with Sun Air representative, David 

Hackett, we are once again struck by the changing landscape ofthe BAS program. Based on 

tbe.~;~e three contributing factors we offer the following comments: 

Our understanding is that Sun Air has submitted an inseparable proposal for Hagerstown, 

Maryland and Lancaster, Pennsylvania offering daily passenger service on nine passenger Piper 

Chieftain aircraft to either Baltimore/Washington International Thurgood Marshall Airport 

(Bwn or Washington Dulles International Airport (JAD), with 24 nonstop round trips a week for 

Hagerstown and 30 nonstop round trips a week for Lancaster, each of which has been proposed 

at different annual subsidy rates. Of these two alternatives only Sun Air's "Service Option 2" 

describing daily service to and from Washington Dulles International Airport (lAD) would be 

acceptable to Hagerstown. 

Having said this, we have many concerns about Sun Air (Operator) and its proposed operation. 

1) The Operator lacks the necessary operating authorities from the:; U.S. Department of 

Transportation {DOT) and the Federal Aviation Administration (FAA) to provide daily 

scheduled passenger operations. · 

2) AB a result the Operator has no experience in providing daily scheduled passenger 

operations. 
MA\'-29-2012 09: 59A FROM: HAGERSTOWtH..JASHINGTO 2403132281 

Dennis DeVany 

May 24,2012 

Page 2 of3 

TO: 91202366763E: 

3) As we understand it, the Operator docs not presently have the aircraft necessary to 

provide this service. Without these, the condition of aircraft interiors and exteriors is 

unknown. 

4) At this time we understand that there is nQ commitment, verbally or otherwise, from BWI 

or lAD (or from their tenants) for the space necessary for this operation. 

5) There is no formal code-sharing or i:nter1ine agreement between any Jegacy carrier or 

major carrier I:Uld the Operator. We believe that such agreements are critical to tbe 

success of the proposed operation. 

6) There appears to be an absence in the Operator's proposal of dollars colllJllitted to the 

marketing and promotion of this new product (the airline) ond these new services (routes, 

schedules. pricing, etc.). Mr. Hackett stated that $25,000 was eannar.ked for this. By 

c::ompadson Cnpe Air's annual commitment to this work: was $40,000. 

7) We find the proposed subsidy mnounts to be excessive for what DOT and the 

communities would be getting. 

While we may be inclined to support the Operator's proposal of the four roundtrips a day to IAD, 

we also have severa.1 concerns related to this. First, we stress our interest in participating in 

detennining the final flight schedule for our community. As in the past tho need remains for a 

very early morning departure from HGR for our business traveJers and for a well timed last 

departure from lAD which would be able to capture those passengers returning from points west. 

These scheduling requirements suggest that the Operator should "originate" its first morning 

departure from HGR. Mr. Hackett stated during our meeting that he purposeJy proposes off-peak 

timing for HGR's arrivals and departures at lAD to pJacate some of the airlines he has been 

speaking with about gate utilization. We believe this to be counterproductive and contrary to our 

objectives to make this service successful and self-sustaining. 

Additionally, Mr. Hackett's comments about his vision of the future ofStm Air struck us as 

alanning. Stating his understanding of the tentative status of the EAS Program and in particular 

the fragility of the eligibility of Hagerstown and Lancaster, Mr. Hackett went on to say he sees 

an opportunity (for one of his other enterprises) to connect our communities to a nearby airport 

"Hub, by shuttle bus once subsidy is gone. We acknowledge the delicateness of our situation 

with the BAS Program but vlcw things very differently. We remain optimistic about HGR's 

ability to grow as commercial service airport and we see the BAS Program as an important tool 

to help get us there. 

In the absence of commitments from BWl or lAD for the space necessary for this operation Mr. 

Hackett has suggested that it may be necessary to start the service at BWI, then once gate space 

has been secured at IAD. to petition DOT to shift the service to lAD. We find this proposition 

unacceptable, 

Jn summary, of the two options submitted by Sun Air Express, ILC d/b/a Sun Air for 

Hagerstown,s EAS contract, only ''Service Option 21t describing daily service to and from 

Washington Dulles International Airport (lAD) would be acceptable to Hagerstown. However, 

given the number and significance of the details that remain unresolved with this proposal. and 

the general Jack of commitments from airport and airline stakeholders, we question if it would 

not he best to reject this proposal in its entirety and rebid these contracts. 
MAY -29-2012 10: 00A FROt1: HAGERSTOWt~-WASHI NGTO 2403132281 

Dennis DeVany 

May24. 2012 

Page 3 of3 

T0:912023557538 

Please note that the Airport,s ultimate objective remains to achieve selfsustainability as a 

commercia] service airport. We appreciate the good work of your Office and the opportunity to 

comment on tho submissions for Hagerstown's BAS contract. Please don't hesitate to contact us 

if you have any other questions. 

P · li . Ridenour, C.M. 

AilJlort Director 

CC: Mr. Brian Swanson