GAO 

United States Government Accountability Office

Report to Congressional Requesters

NATIONAL 

TRANSPORTATION 

SYSTEM 

Options and Analytical 

Tools to Strengthen 

DOT’s Approach to 

Supporting 

Communities’ Access 

to the System 

July 2009 

GAO-09-753 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 2009

NATIONAL TRANSPORTATION SYSTEM

Options and Analytical Tools to Strengthen DOT’s

Approach to Supporting Communities’ Access to the 

Highlights of GAO-09-753, a report to System 

congressional requesters 

Since 1978, the Essential Air 

Service (EAS) program has 

subsidized air service to eligible 

communities that would otherwise 

not have scheduled service. The 

cost of this program has risen as 

the number of communities being 

served and subsidies to air carriers 

have increased. At the same time, 

the number of carriers providing 

EAS service has declined. Given 

continuing concerns over the EAS 

program’s long-term prospects, 

GAO was asked to review the 

program. 

GAO reviewed (1) the 

characteristics and current status 

of the EAS program, (2) factors 

affecting the program’s ability to 

provide air service, (3) options for 

revising the program, and (4) tools 

for assessing the program, the 

options for its revision, and the 

program’s performance. GAO 

interviewed stakeholders and 

reviewed the results of an expert 

panel convened by GAO, 

Department of Transportation 

(DOT) data and program 

documentation, and potential 

methodologies for assessing 

federal programs. 

What GAO Recommends

Congress should consider reexamining the EAS program in light 

of changes in its operating 

environment, and DOT should 

assess some of its practices as well 

as whether other forms of air 

service or other modes of 

transportation might better serve 

some communities. DOT 

concurred with our revised 

recommendations. 

The EAS program has changed relatively little in 30 years, but current 

conditions raise concerns about whether the program can continue to operate 

as it has. Over the past 2 years subsidies to carriers have been increasing, 

along with EAS program obligations to fund those subsidies. In response, the 

administration is requesting $175 million for the EAS program in fiscal year 

2010, a $50 million increase over recent funding levels. At the same time, the 

number of carriers providing subsidized air service is declining, from 34 in 

1987 to 10 in 2009. More than one-third of the EAS-supported communities 

temporarily lost service in 2008, when 3 carriers ceased operations. 

Several factors contribute to the increasing difficulty in providing subsidized 

air service. The EAS program has statutory requirements for minimum 

aircraft size and frequency of flights, effectively requiring carriers to provide 

service that may not be “right-sized” for some small markets. Also, the growth 

of air service especially by low-cost carriers—which today serve most U.S. 

hub airports---weighed against the relatively high fares and inconvenience of 

EAS flights, can lead people to bypass EAS flights and drive to hub airports. 

Moreover, the continued urbanization of the United States may have eroded 

the potential passenger base in some small and rural EAS communities. 

While Congress, DOT, GAO, and others have proposed various revisions to the 

EAS program, Congress has not authorized many changes to program 

requirements. Proposed Federal Aviation Administration reauthorization 

legislation would include performance-based incentives, among other 

changes. GAO and others have suggested increasing flexibility and other 

changes that could make EAS service more sustainable for smaller 

communities. Finally, members of an expert panel organized by GAO all 

believed that small and rural communities would benefit from a multimodal 

approach to transportation. Generally they believed that other modes of 

transportation could be more responsive to communities’ transportation 

needs in some cases. 

Although it is difficult to select options for the EAS program since 

stakeholders do not always agree on program objectives, certain analytical 

tools can help policymakers assess the EAS program. Tools include a reexamination framework to revisit the program’s objectives, and help evaluate 

options to make the program more effective. Other analytical tools include an 

analytical approach GAO developed that, for a sample of small and rural 

communities, identified their access to different modes of transportation. 

This approach has the potential for broader application to examinations of 

communities’ access to the national transportation network. Finally, once a 

change is implemented, performance measures can be used to periodically 

evaluate program effectiveness. 

View GAO-09-753 or key components.

For more information, contact Gerald 

Dillingham at (202) 512-2834 or 

dillinghamg@gao.gov. 
Page i GAO-09-753 

Contents 

Letter 1

Background 3 

The EAS Program Is Providing Air Service to More Communities, 

but Service Is Costing More and the Number of Carriers 

Providing Service Is Declining 9 

The EAS Program’s Ability to Provide Service Is Affected by the 

Financial Viability of Service on EAS Routes 14 

Options for Modifying the EAS Program and Instituting a Multimodal Approach to Community Transportation 25 

Selecting Options for the EAS Program Is Difficult, but Tools Exist 

for Assessing the Options and Improving Program Evaluation 36 

Conclusions 42 

Matters for Congressional Consideration 43 

Recommendations for Executive Action 43 

Agency Comments 43 

Appendix I Objectives, Scope and Methodology 45 

Appendix II Panelist Responses to GAO Questionnaire 49 

Appendix III 21st Century Questions for Program Re-examination 56 

Appendix IV Geographic Information Systems Analysis of Small 

Community Transportation Access 58 

Appendix V GAO Contact and Staff Acknowledgments 71 

Tables 

Table 1: Potential Options to Revise the Essential Air Service 

Program 26 

Table 2: Responses to GAO’s Questionnaire 49 

 National Transportation System 
Figures 

Figure 1: Location of EAS Communities as of January 1, 2009 4 

Figure 2: Total Obligations, Fiscal Years 2003–2008 10 

Figure 3: EAS Appropriations, Fiscal Years 2003–2009 12 

Figure 4: Example of a Beechcraft 1900 Series Turboprop Aircraft 15 

Figure 5: Average Fuel Prices for Selected EAS Carriers, Jan. 2007–

Dec. 2008 18 

Figure 6: Changes in Population Distribution, 1980–2007 21 

Figure 7: Example of a 9-seat Cessna 402 Aircraft 28 

Figure 8: Changes in Distribution of Population, 1980 to 2007 59 

Figure 9: Access to Transportation: Air Transport Only 63 

Figure 10: Access to Transportation: Major Highway Access 64 

Figure 11: Access to Transportation: Passenger Rail 65 

Figure 12: Access to Transportation: All modes, Weighted Equally 66 

Figure 13: Access to Transportation: Current EAS Communities 

and Other Selected Communities’ Access to Medium- and 

Large-Hub Airports 68 

Figure 14: Access to Transportation: Communities with Access to 

Airports Served by Low-Cost Carriers 69 

Abbreviations 

AIR-21 Wendell H. Ford Aviation Investment and Reform Act for 

 the 21st Century 

DOT Department of Transportation 

FAA Federal Aviation Administration 

GIS Geographic Information Systems 

GPRA Government Performance and Results Act of 1993 

EAS Essential Air Service 

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page ii GAO-09-753 National Transportation System
Page 1 GAO-09-753 

United States Government Accountability Office

Washington, DC 20548 

 

July 17, 2009 

The Honorable John L. Mica 

Ranking Republican Member 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Thomas E. Petri 

Ranking Republican Member 

Subcommittee on Aviation 

Committee on Transportation and Infrastructure 

House of Representatives 

In 1978, Congress deregulated the airline industry and established the 

Essential Air Service (EAS) program to ensure that communities that had 

air service at the time of deregulation would continue to receive at least a 

minimum level of service. Under the EAS program, if an air carrier cannot 

provide air service to eligible communities without incurring a loss, the 

Department of Transportation (DOT) awards the air carrier a subsidy to 

serve those communities. In 2008, this program helped support 

commercial air service to about 150 communities throughout the United 

States. The prospects for the EAS program are a matter of concern to 

many Members of Congress. In April 2009, 22 Senators submitted a letter 

to the Director of the Office of Management and Budget requesting that 

the administration’s budget request “reflect the priority of the EAS 

program to rural America . . .” The administration, in its fiscal year 2010 

budget request for DOT notes that the current EAS program is not 

efficiently designed, and states its intent to work with Congress to develop 

a sustainable program that will fulfill its commitment while enhancing 

convenience for travelers and improving cost effectiveness. 

Many factors appear to be contributing to increased operating costs for 

EAS carriers and increasing demand from communities, leading to higher 

subsidy costs for the EAS program. The administration’s fiscal year 2010 

budget request includes increased funding for this upcoming year to help 

cover the costs of increased demand for the program. In addition, over the 

years Congress has expressed concern that changes in the aviation 

industry and rising costs may jeopardize the EAS program’s long-term 

 National Transportation System 
 

viability. Finally, in a 2002 report,1 we also identified several factors that 

were likely in the near term to create pressure to increase potential future 

subsidy requirements of the EAS program, and described various options 

that could promote the long-term viability of the program. 

Given continuing concerns over the EAS program’s long-term prospects, 

you asked us to review the program. This report addresses (1) the 

characteristics and current status of the program, (2) the factors affecting 

its ability to provide service to communities, (3) options for revising the 

EAS program, and (4) tools for assessing the program, options for its 

revision, and the program’s performance. To complete this work we 

reviewed previous reports and studies of the EAS program, including 

previous GAO reports. We also held a panel discussion attended by 

experts on community air service including airline officials, program 

administrators, economists, other transportation providers, and state and 

local officials. These experts discussed the factors affecting the EAS 

program and options for providing service to communities across the 

country, in addition to responding to our questions about the federal 

government’s options for assisting communities with connecting to the 

national transportation system. We gathered information on the 

experiences of airports served by the EAS program from a national 

association of airports, and from seven of their member airports. We 

obtained DOT data on the EAS program. Our review focuses on 

communities within the continental United States that have received EAS 

subsidized service. We focused our review on these communities because 

the requirements for communities in Alaska are different than for 

communities in other states, and airports outside the contiguous states 

and are not representative of the program in the rest of the country.2

 In 

identifying tools for assessing the program, options for its revision, and the 

program’s performance, we compared the program status to GAO’s reexamination criteria and compared DOT’s performance measures for this 

program against the criteria of the Government Performance and Results 

Act of 1993 and the Office of Management and Budget’s Program 

Assessment Rating Tool. We found DOT’s data sufficiently reliable for 

providing status information on the program. 

 

1

GAO, Options to Enhance the Long-term Viability of the Essential Air Service Program, 

GAO-02-997R (Washington, D.C.: Aug. 30, 2002). 

2

EAS operations to communities in Alaska are subject to different requirements (e.g., 

carriers may use smaller aircraft) and special provisions. 

Page 2 GAO-09-753 National Transportation System
 

We conducted this performance audit from March 2008 through July 2009 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believed that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. See appendix I for more details 

on our scope and methodology. 

In 1978, Congress deregulated the airline industry, phasing out the federal 

government’s control over domestic fares and routes served and allowing 

market forces to determine the price, quantity, and quality of service. Free 

to determine which communities they would serve, as well as what fares 

they would charge, most major carriers became “network” carriers, 

developing “hub-and-spoke” networks and providing service from their 

hubs to many “spoke” cities they served. Anticipating that airlines would 

be free to focus their resources on generally more profitable high-density 

markets, Congress became concerned that major carriers would eliminate 

their less profitable routes serving smaller communities, causing these 

communities to lose air service. In response, Congress established the 

Essential Air Service (EAS) program as part of the Airline Deregulation 

Act of 1978. The EAS program subsidizes commercial air service for 

communities that would otherwise have lost service as a result of 

deregulation. The law specifies that if an air carrier cannot continue 

service to a community without incurring a loss, DOT shall then use EAS 

program funds to award a subsidy to that carrier or another carrier willing 

to provide service. Congress initially enacted the program for 10 years, and 

later extended it for another 10 years. In 1996, Congress removed the 10-

year time limit.3

Background 

Under the Airline Deregulation Act, communities that were eligible for air 

service on October 24, 1978, are eligible for EAS-subsidized service.4

 There 

are EAS-eligible communities in 49 states, Puerto Rico, and American 

 

3

Section 278 of the Federal Aviation Reauthorization Act of 1996, Pub. L. No. 104-264 

(Oct. 9, 1996) amended 49 USC § 41742, eliminating an expiration date for the EAS program 

of September 30, 1998. 

4

Communities did not have to be actively receiving air service in 1978 to be eligible for 

EAS, but they did have to be listed on an air carrier certificate. These certificates, issued 

under 49 USC § 41102, authorized a carrier to provide scheduled service along particular 

routes between named communities. 

Page 3 GAO-09-753 National Transportation System
 

Samoa.5 As of November 2008, DOT had agreements with carriers to 

provide subsidized service to almost 150 communities—102 in the 

continental United States, 43 in Alaska, and 2 in Puerto Rico.6

 Not all 

communities that are eligible for EAS service currently receive it; many 

currently have unsubsidized air service. Figure 1 shows the communities 

that had access to EAS service as of January 1, 2009, or are projected to 

have service starting later in the year. 

ojected to 

Figure 1: Location of EAS Communities as of January 1, 2009 

EAS communities (102)

Source: GAO’s analysis of DOT data.

 

5

There are no EAS-eligible communities in Delaware. 

6

Includes agreements awarded as of November 2008, for which service had not yet begun 

as of that month. 

Page 4 GAO-09-753 National Transportation System
 

Communities near airports with EAS service vary in their population. For 

example, 58 percent of the communities within 40 miles of an airport with 

EAS-subsidized service as of January 1, 2009, had a population of less than 

10,000 while 2 percent had a population of over 100,000. 

A multistep process is required for subsidized EAS service to begin at a 

community. For a community that is not currently receiving EAS 

subsidies, the process starts when the last air carrier providing 

unsubsidized service to an EAS-eligible community files a Notice of 

Termination, which is a 90-day notice of its intent to suspend, terminate, 

or reduce service below the minimum level of service required by law. If 

no other air carrier is willing to provide unsubsidized air service to the 

community, DOT solicits proposals from carriers that would be willing to 

provide service with a subsidy. Carriers requesting a subsidy must 

document that they cannot profitably serve the community without a 

subsidy by submitting various financial data, such as profit-or-loss 

statements, to DOT. DOT then reviews these data along with information 

about the aviation industry’s pricing structure, the size of aircraft required, 

the amount of service required, and the number of projected passengers 

who would use this service. DOT also considers the community’s 

preferences for the proposed service. Finally, DOT selects a carrier based 

on statutory selection criteria and sets an annual subsidy amount intended 

to compensate the carrier for the amount by which its projected operating 

costs exceed its expected passenger revenues as well as a profit element 

of at least 5 percent of total operating expenses, according to statute.7

Once air service is under way, DOT makes monthly subsidy payments to 

the carrier based on the number of scheduled flights completed. DOT’s 

agreement with the carrier is subject to renewal generally every 2 years, at 

which time other air carriers are permitted to submit proposals to serve 

that community with or without a subsidy. 

In general, the law currently requires that an EAS carrier provide the 

following: 

• service to a hub airport, defined as an Federal Aviation Administration 

(FAA)-designated medium- or large-hub airport; 

 

7

Air carriers are awarded fixed-rate contracts, subject to adjustment based on flights 

actually completed. The carriers are free to set and adjust the fares charged passengers for 

EAS flights. 

Page 5 GAO-09-753 National Transportation System
 

• two daily round trips, 6 days a week, with not more than one intermediate 

stop to the hub; 

• flights at reasonable times taking into account the needs of passengers 

with connecting flights; 

• service in an aircraft with an effective capacity of at least 15 passengers, 

under certain circumstances,8

 unless the affected community agrees in 

writing to the use of smaller aircraft; 

• service in aircraft with at least two engines and using two pilots; and 

• service with pressurized aircraft under certain circumstances.9

Congress and DOT revised the program’s eligibility requirements during 

the late 1980s and early 1990s, in response to insufficient program funding. 

For example, in June 1989, Congress prohibited DOT, beginning in fiscal 

year 1990, from subsidizing service to or from any essential air service 

point in the contiguous 48 states where the subsidy exceeded $300 per 

passenger.10 In December 1989, DOT implemented a regulation that, 

among other requirements, would eliminate EAS funding for communitie

that had EAS service with a per-passenger subsidy exceeding $200 per 

person, or that were located less than 70 highway miles from the nearest 

medium- or large-hub airport, if appropriations for the EAS program were 

less than the amount needed to maintain EAS service at the communiti

being served.

s 

es 

99012

 

11 The Aviation Safety and Capacity Expansion Act of 1

superseded this regulation by prohibiting DOT from declaring any 

community ineligible for any reason not specifically set forth in statute.13

Finally, in fiscal year 1994, Congress prohibited DOT from subsidizing 

8

Aircraft with at least 15-passenger capacity are required for communities that averaged 

more than 11 daily boardings in any year from 1976 through 1986, according to DOT 

guidance. 

9

49 USC 41732(b)(6). Service is to be provided by pressurized aircraft, when that service is 

provided by aircraft that regularly fly above 8,000 feet in altitude. 

10The Dire Emergency Supplemental Appropriations Act of 1989, Pub. L. No. 101-45 (June 

30, 1989). 

1114 CFR § 398.11 (1989). 

12Pub. L. No. 101-508 (1990). 

13Codified in 49 USC § 41731(b). 

Page 6 GAO-09-753 National Transportation System
 

service to communities that (1) are less than 70 highway miles from the 

nearest medium- or large-hub airport, or (2) require a per-passenger EAS 

subsidy in excess of $200.14 Communities located more than 210 miles 

from the nearest medium- or large-hub community airport are exempt 

from this $200-per-passenger subsidy limit. 

 

Over the years, several communities have lost eligibility for EAS service 

for various reasons. In some instances—after the requirements went into 

effect—-it was because the per-passenger subsidy for their service 

exceeded the allowable limit, or because the community was less than 70 

miles from a medium- or large-hub airport. Other communities lost EAS 

service in the early 1990s as Congress took actions to address program 

funding constraints. DOT monitors participating air carriers’ operations to 

help ensure their service complies with program requirements. For 

example, DOT periodically reviews carriers’ enplanement data for the EAS 

routes carriers serve, to determine whether the carriers’ per-passenger 

subsidy exceeds the statutory cap of $200. Because DOT’s subsidy 

payments to carriers are based on the number of flights completed, 

regardless of the number of passengers on board, an EAS route with few 

passengers has a higher per-passenger subsidy than it would have with 

more passengers. When DOT does find that a carrier’s subsidy per 

passenger exceeds $200 for an EAS route, the agency warns the 

community of its tentative decision to terminate the route subsidy and 

allows the community 20 days to object if the community finds that DOT 

has made a mistake in its calculations. Since 1989, 61 communities have 

lost EAS service because they became ineligible to receive subsidized 

service. 

• Twenty-six communities lost service in fiscal year 1990 as a result of 

reduced program funding. Six of these communities lost service as 

October 1989 because their carrier’s subsidy per passenger exceeded the 

$300 limit then in effect, and 20 more lost service as of January 1990 

because their carrier’s per-passenger subsidy was over $200. 

• Twelve communities lost service in fiscal year 1994, a year when funding 

for the EAS program was reduced, because their carrier’s per-passenger 

14Department of Transportation and Related Agencies Appropriations Act for fiscal year 

1994, Pub. L. No. 103-122 (Oct. 27, 1993). This provision was repeated in DOT 

appropriations acts for fiscal years 1995 through 1999. The provision was made permanent 

in the Department of Transportation appropriations act for fiscal year 2000. 

Page 7 GAO-09-753 National Transportation System
 

subsidy exceeded $200 or because they were within 70 miles of a mediumor large-hub airport. 

• Twenty-two more communities became ineligible at various times since 

fiscal year 1995 because their carrier’s per-passenger subsidy exceeded 

$200. 

• One community became ineligible to receive subsidized service in 1995 

because a nearby small hub was reclassified as a medium hub. 

Also, 11 communities that were not receiving EAS-subsidized service lost 

their eligibility for EAS service when the last unsubsidized carrier filed to 

suspend service at their airport and DOT determined that the community 

was ineligible because it was within 70 miles of a medium- or large-hub 

airport. 

Finally, in addition to EAS, other DOT programs can support community 

air service. Congress authorized the Small Community Air Service 

Development Program in 2000 as a pilot program in the Wendell H. Ford 

Aviation Investment and Reform Act for the 21st Century (AIR-21)15 to 

help small communities enhance their air service. AIR-21 authorized

program for fiscal years 2002 and 2003, and subsequent legislation

 the 

 

16

reauthorized the program through fiscal year 2008 and eliminated its 

“pilot” status. Through the Small Community Air Service Development 

Program, DOT may award up to 40 grants each year to communities with 

non- or small-hub airports that have demonstrated air service deficiencies 

or higher than average fares. Communities use these grants to pursue 

different strategies to enhance air service. Such strategies have included 

offering subsidies or revenue guarantees to airlines, marketing, and hiring 

personnel.17 In addition, under the Airport Improvement Program, small 

airports receive certain funds to make capital improvements—such as 

runway and taxi improvements. 

15Pub. L. No. 106-181 (Apr. 5, 2000). 

16Vision 100—Century of Aviation Reauthorization Act, Pub. L. No. 108-176 (Dec. 12, 2003). 

17GAO, Commercial Aviation: Initial Small Community Air Service Development 

Projects Have Achieved Mixed Results, GAO-06-21 (Washington, D.C.: Nov. 30, 2005). Also, 

DOT-OIG, The Small Community Air Service Development Program, CR-2008-051, May 

13, 2008. 

Page 8 GAO-09-753 National Transportation System
 

The EAS Program Is 

Providing Air Service 

to More Communities, 

but Service Is Costing 

More and the Number 

of Carriers Providing 

Service Is Declining 

EAS Program Obligations 

and Appropriations Have 

Generally Increased to 

Support Service to More 

Communities and Higher 

Carrier Subsidies 

The number of communities served by the EAS program in the continental 

United States has risen in recent years— from 87 communities as of June 

1, 2003, to 102 communities18 as of November 1, 2008.19 The subsidies that 

carriers require to serve those routes have also increased since 2003, 

adding to the long-term cost of the EAS program. For example, the 

average annual subsidy DOT has awarded for EAS service per community 

in the continental United States increased from about $883,000 as of June 

2003 to about $1,371,000 as of November 2008. After adjusting this growth 

for the effects of inflation, the average EAS subsidy in 2008 was about 35 

percent higher than in 2003. 

In addition, significant increases in carrier subsidies per community have 

come within the past 2 years. Between November 2007 and November 

2008, DOT renewed or awarded agreements to 57 communities in the EAS 

program in the continental United States, with the total annual subsidy for 

those communities increasing from $52.4 million to $86.3 million (in 

nominal dollars)—an increase of 65 percent. For many of these routes, the 

carrier’s annual subsidy amount more than doubled. 

 

18This includes 6 communities for which DOT had an agreement with a carrier to begin 

service, but the carrier subsequently withdrew before service began. 

19While the number of communities served has increased, the number of passengers on 

EAS flights has been relatively stable in recent years, declining somewhat in 2008. 

According to DOT, approximately 1.04 million passengers flew EAS flights in fiscal year 

2003, compared to 1.10 million passengers in calendar year 2007. (EAS passenger data were 

not available on a comparable year basis for all years). The number of EAS passengers in 

calendar year 2008 decreased to about 960,000. The economic decline toward the end of 

2008 and service interruptions in 2008 may largely account for this decrease. 

Page 9 GAO-09-753 National Transportation System
 

While the number of EAS communities and the amount of subsidies have 

increased, annual obligations ranged between $103 million and $114 

million (in nominal dollars) from fiscal year 2003 through fiscal year 

2007.20 In fiscal year 2008, obligations for EAS subsidies increased to about 

$116 million. An additional $31 million in balances from completed EAS 

agreements that could not be retained for the EAS program was returned 

to FAA, bringing total obligations to $147 million as shown in figure 2. 

ed for the EAS program was returned 

Figure 2: Total Obligations, Fiscal Years 2003–2008 

0

20

40

60

80

100

120

140

160

2003 2004 2005 2006 2007 2008

Dollars (in millions)

Source: GAO’s analysis of DOT data.

Fiscal year

Indexed for inflation

Obligated amount

Note: Includes obligations for the entire program. 

EAS program obligations in fiscal year 2008 were less than they potentially 

could have been because DOT did not have to subsidize certain EAS 

carriers that ceased operations and discontinued service to several 

 

20While our review focuses on EAS service in the 48 contiguous states, obligations are 

reported for the EAS program as a whole, including obligations for Alaska, Hawaii, and 

Puerto Rico. However, EAS service outside of the 48 contiguous states does not represent a 

large portion of EAS program funding—DOT estimates service to these locations 

accounted for about 8 percent of total program subsidies as of 2008. 

Page 10 GAO-09-753 National Transportation System
 

communities. Specifically, in the first 6 months of 2008, three carriers 

serving 37 communities ceased operations.21 Most of these communities 

were without service for several months because replacement carriers 

were not able to start up immediately. 

Keeping pace with the rising financial requirement to manage the program, 

total appropriations for the EAS program have generally increased in 

recent years.22 Total appropriations have increased from about $102 

million in fiscal year 2003 to just over $124 million in fiscal years 2007 and 

2008. For fiscal year 2009, appropriations available for the program 

include $123 million in fiscal year 2009 appropriations and a supplemental 

appropriations act which provides an additional $13.2 million in fiscal year 

2009 supplemental funding for the EAS program.23 This increases EAS’s 

fiscal year 2009 appropriations to $136.2 million.24 The administration has 

requested about $175 million for the program in 2010, which would 

represent a further increase in program funding. 

EAS program funding comes from multiple sources. Each year, the EAS 

program receives $50 million in overflight fees.25 Recently, Congress also 

has annually appropriated additional funds from the Airport and Airway 

Trust Fund and has supplemented these EAS program funds in 2005, 2007, 

2008, and 2009 with additional appropriations, as shown in figure 3. DOT 

had requested additional funding for 2005, 2007, and 2008 to account for 

the higher dollar amounts required to reimburse carriers for serving EAS 

communities. For example, in fiscal year 2005, DOT transferred $5 million 

from the Small Community Air Service Development Program, which 

 

21In addition, a fourth carrier ceased operations in early 2007, affecting 11 communities. 

22As with obligations data, appropriations data are for the entire EAS program, including 

Alaska, Hawaii, and Puerto Rico. 

23Pub. L. No. 111-32, title XII (June 24, 2009). In Pub. L. No. 111-32, in addition to $13.2 

million being made available for EAS, $13.2 million was rescinded by Congress from the FY 

2008 Airport Improvement Program account. 

24According to DOT officials, an additional $14 million from previous years’ appropriations 

also is available to be expended in fiscal year 2009 if needed. 

25Beginning in fiscal year 1998, Congress funded the EAS program at $50 million a year 

from overflight fees assessed through the Rural Air Service Survival Act, which is part of 

the Federal Aviation Administration Reauthorization Act of 1996, Pub. L. No. 104-264 

(Oct. 9, 1996). Overflight fees are user fees for air traffic control services provided by FAA 

to aircraft that fly over, but do not land in the United States. 

Page 11 GAO-09-753 National Transportation System
 

provides grants to enhance small communities’ air service, to help fund the 

EAS program’s increased costs.26

Figure 3: EAS Appropriations, Fiscal Years 2003–2009 

Dollars (in millions)

Fiscal year

Supplement appropriations

Congressional appropriations

Overflight fees

0

20

40

60

80

100

120

140

2002 2003 2004 2005 2006 2007 2008 2009

Source: GAO’s analysis of DOT data and appropriations acts.

Recently, DOT officials have been concerned about whether the EAS 

program has sufficient funding to serve both current EAS communities 

and additional communities that may be eligible for subsidized service. 

The EAS program is appropriated a specific amount each fiscal year. 

However, since fiscal year 2005, language has been included in 

appropriations legislation stating that if the annual amount provided for 

EAS is insufficient to meet the costs of the EAS program in the current 

fiscal year, the Secretary of the Department of Transportation is required 

to transfer funds to EAS from any other amounts appropriated to or 

 

26Emergency Supplemental Appropriations for Defense, the Global War on Terror, and 

Tsunami Relief, 2005, Pub. L. No. 109-13 § 6064 (May, 11, 2005). 

Page 12 GAO-09-753 National Transportation System
 

directly administered by the Office of the Secretary.27 This would require 

DOT to draw upon other funding sources within the Office of the 

Secretary to be able to make payments to carriers and enter into new 

service agreements. DOT had to do this once, using some Small 

Community Air Service Development Program funding for the EAS 

program in 2005. In addition, a DOT official noted that the EAS program 

faces a significant potential financial liability, in that there are about 40 

other EAS-eligible communities in the country with airports currently 

served by a single unsubsidized commercial carrier. DOT officials believe 

that the agency would encounter a significant financial liability—about $60 

million annually—if the airlines serving these single-carrier airports all 

filed a Notice of Termination requiring DOT to subsidize continued 

service. In fact, three communities that have not previously had EAS 

service have come into the program since June 2008, and a fourth is 

expected to obtain subsidized service later this year. 

Carrier Withdrawals from 

the Program in 2008 

Caused Service 

Interruptions for Many 

Communities, While 

Others Still Do Not Have 

EAS Service Restored 

According to a DOT official, the EAS program has recently experienced an 

unusually high level of carrier turnover. In 2008 alone, three EAS carriers 

serving 37 communities ceased operations in the first 6 months of the year. 

According to a DOT official, various factors caused the three carriers to 

cease operations, and recent fuel price increases might have accelerated 

this situation. DOT was able to obtain a replacement carrier to continue 

service, without interruption, for one of the 37 communities. However, 30 

of the other 36 communities were temporarily without EAS air service for 

up to 10 months, and 6 communities28 are still without service because the 

carrier that DOT selected in 2008 to serve those communities withdrew 

before it started service. An official of the carrier stated that it withdrew 

because it was unable to finance the refurbishing of aircraft needed to 

serve those routes. In late June 2009, DOT awarded agreements to two 

carriers to provide EAS service to these 6 communities; dates for the start 

of service had not been set. 

 

27See, e.g., the Transportation, Treasury, and Housing and Urban Development, the 

Judiciary, District of Columbia, and Independent Agencies Appropriations Act, Fiscal Year 

2006. Pub. L. No. 109-115, 119 Stat. 2396, 2398 (Nov. 30, 2005). Also, Pub. L. No. 109–13 § 

6064 (May 11, 2005). 

28El Dorado/Camden, Harrison, Hot Springs, and Jonesboro, Arkansas; Jackson, Tennessee; 

and Owensboro, Kentucky. 

Page 13 GAO-09-753 National Transportation System
 

A DOT official noted that while the number of communities that 

experienced carrier turnover in 2008 was unprecedented, the number of 

carriers providing air service to communities under the EAS program has 

actually been declining over many years. The number of carriers providing 

EAS service has declined from 34 as of February 1987 to 10 in 2009. In 

addition, as the number of carriers has declined, the percentage of EAS 

routes served by just a few carriers has increased. In February 1987, the 

largest number of routes served by any one carrier was 13, and the four 

carriers that served the most communities accounted for 33 percent of the 

EAS routes. At present, four carriers serve about 85 percent of the routes 

in the EAS program, with a single carrier serving nearly half of the EAS 

routes. As noted above, one carrier recently withdrew from 6 EAS routes 

that it was awarded last year before it even started service. Also, DOT 

faces a potential rise in the number of communities requiring subsidized 

air service should their single unsubsidized carrier end operations. Should 

additional EAS carriers withdraw from the program or be financially 

unable to serve additional communities seeking EAS service—the 

remaining carriers may not have enough capacity to provide EAS service 

to all communities that qualify. 

The EAS Program’s 

Ability to Provide 

Service Is Affected by 

the Financial Viability 

of Service on EAS 

Routes 

Page 14 GAO-09-753 National Transportation System
 

Many of the expert panelists and other stakeholders we interviewed stated 

that some EAS program requirements significantly add to the cost of 

providing subsidized air service to communities. For example, members of 

our expert panel thought the EAS mandate requiring carriers to use 

aircraft with a 15-seat capacity for most communities presented the 

biggest challenge to providing and sustaining air service to communities 

under the EAS program.29 The mandate requires carriers to use larger 

aircraft than may be needed to adequately serve some communities. In 

addition, the 15-seat aircraft that this requirement was based upon are no 

longer available. Currently, to satisfy the 15-seat minimum, most EAS 

routes are served by 19-seat twin-engine turboprop aircraft. (See fig. 4 for 

an example of a 19-seat twin-engine turboprop aircraft.) 

 4 for 

Program Requirements 

and Other Factors Appear 

to Contribute to Increasing 

Costs of EAS Service for 

Carriers and Higher 

Program Subsidies from 

DOT 

Figure 4: Example of a Beechcraft 1900 Series Turboprop Aircraft 

Source: Great Lakes Aviation.

According to industry representatives, these 19-seat turboprop aircraft 

used on many EAS routes are relatively costly to operate. First, the aircraft 

are no longer in production, are in limited supply, and are also relatively 

costly to acquire and refurbish to comply with current operating 

standards. Second, the “Commuter Safety Rule” which FAA implemented 

in 1997, has increased EAS carriers’ costs for operating 19-seat turboprop 

 

29For most EAS-eligible communities, the law requires carriers to provide service with 

aircraft of at least 15-passenger capacity, two engines, and carrying two pilots, unless the 

community served agrees to accept service with smaller aircraft. 

Page 15 GAO-09-753 National Transportation System
 

aircraft. Through the rule, FAA intended to increase safety by requiring 

aircraft in the 10-to-30 passenger range to meet more stringent safety 

requirements.30 The increased safety standards made some aircraft, 

including 19-seat turboprop aircraft, more costly to operate, because they 

required carriers to improve ground deicing programs, carry additional 

safety equipment for passengers, and comply with additional operating 

constraints. For example, an industry group, in a petition to DOT for 

exemptions from this rule, provided information showing that one EAS 

carrier’s training costs increased by almost 600 percent because of the 

additional training required for its captains by the revised rule. An EAS 

carrier official stated that the carrier’s cost to operate 19-seat aircraft, 

calculated as cost per passenger seat mile, is now about twice what it was 

in 1994 primarily due to these additional regulatory requirements. 

According to industry representatives, the increased operating costs 

associated with the required safety upgrades have contributed to some 

carriers’ decisions to eliminate their inventory of 19-seat planes. As a 

result, there are fewer airlines with the type of equipment suitable to serve 

most EAS routes. 

The EAS minimum service requirements may also require a carrier to 

provide more service than needed to meet the demands of a community 

and can therefore increase the carrier’s operating costs. For example, the 

EAS program statutes stipulate a minimum level of service for EAS 

subsidized routes—two daily round-trip flights, 6 days per week to a hub 

airport. Carriers flying 19-seat aircraft can be effectively locked into 

service that may not be right sized—that is, with capacity exceeding 

passenger demand—for some smaller markets, and possibly more costly 

than necessary to fulfill communities’ service needs.31 If the need to meet 

EAS program requirements results in carriers providing more capacity 

than some communities might be able to support, EAS service to those 

communities may be too costly for the carrier, leading it to withdraw from 

the EAS program. 

 

30The change required these aircraft to meet more stringent FAR part 121 requirements, 

rather than part 135 requirements. 

31DOT officials indicated there are generally no environmental issues with the 19-seat 

airplanes. Further, historically, turboprop aircraft generally are more fuel efficient, and 

thus have lower emissions, than jets. However, flying planes with few passengers may not 

be fuel efficient. 

Page 16 GAO-09-753 National Transportation System
 

Further, the carriers’ 2-year agreements with DOT to provide EAS service 

can complicate the carriers’ efforts to lease aircraft to serve EAS routes. 

For example, some industry officials maintain that the 2-year agreements 

that DOT enters into with carriers can be too short because carriers often 

must lease aircraft for longer periods, such as 5 years. Therefore, a carrier 

entering into a 5-year lease to obtain aircraft to serve EAS routes risks 

having to maintain excess aircraft if it loses the routes after 2 years. 

However, DOT officials note that under the EAS program’s current funding 

structure, longer-term agreements would still be subject to availability of 

annual funding, so the agreement would not be guaranteed. 

Finally, spikes in fuel prices may add to EAS carriers’ costs and make it 

difficult to continue service. Although fuel prices typically vary over time, 

in 2008 fuel began to comprise an increasing portion of airlines’ costs, in 

some cases contributing to carriers ceasing operations. For example, one 

EAS carrier reported that its fuel costs increased from 28 percent of its 

operating costs in 2007 to 35 percent of its operating costs in 2008, 

although fuel prices began to decline late that year. We also found that last 

year, selected EAS carriers experienced a rapid and dramatic spike in fuel 

prices, as the average per-gallon fuel price for selected EAS carriers more 

than doubled between January 2007 and July 2008, before declining 

through December 2008, as illustrated in figure 5. December 2008 was that 

latest month for which fuel price data were available for these carriers. 

Page 17 GAO-09-753 National Transportation System
 

Figure 5: Average Fuel Prices for Selected EAS Carriers, Jan. 2007–Dec. 2008 

0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. Jan.Dec. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. Dec.

Dollars per gallon

Source: GAO’s analysis of data from BACK Aviation Solutions, Inc.

2007 2008

Note: The average fuel price reflects total fuel price and gallons used data from Atlantic Southeast 

Airlines, Horizon Air, SkyWest Airlines, Mesaba Airlines, and Mesa Airlines, which provide both EAS 

subsidized and unsubsidized commercial service. Therefore, average fuel prices are not based solely 

on the carriers’ EAS operations. 

Legislation passed in 2003 explicitly provided DOT with the option of 

adjusting the subsidy paid to an EAS carrier if the carrier’s expenses 

substantially increased.32 However, according to an industry group that 

represents regional airlines and the majority of EAS carriers, DOT officials 

are generally not willing to renegotiate EAS agreements to reflect 

increased costs because the DOT officials are concerned about retaining 

sufficient funds to renegotiate the agreements and provide service for all 

the communities that may qualify for service. DOT officials indicated they 

are also concerned that establishing a policy of renegotiating subsidies 

upward for fuel costs could lead carriers to underestimate fuel costs in 

order to be selected as the carrier for a route, only to turn around soon 

after selection and ask for fuel rate relief. However, industry officials 

explained that if a carrier is unwilling to continue providing service under 

 

32DOT, using existing general authority under 49 USC § 41733, had provided across-theboard rate relief after the first Gulf War and after the terrorist attacks of September 11, 

2001. 

Page 18 GAO-09-753 National Transportation System
 

an EAS agreement because of operating cost increases, the carrier’s only 

recourse is to file a formal Notice of Termination with DOT of its intent to 

terminate service. For example, in June 2008, Mesaba Airlines filed such a 

notice informing DOT of its intent to terminate service at two communities 

in Michigan because of fuel price increases. Mesaba indicated that it 

would withdraw the notice if DOT agreed to apply a fuel adjustment to 

bring the EAS subsidy rate for the communities in line with current fuel 

conditions. DOT denied the request and rebid the routes. DOT eventually 

reselected Mesaba Airlines to serve the routes and awarded the airline a 28 

percent increase over its previous annual subsidy for the routes. Still, 

industry and small airport officials said that filing a termination notice is 

an undesirable option for airlines because service interruptions and carrier 

turnover can negatively affect communities’ confidence in EAS service, 

and result in a further reduction in ridership. 

The Declining Number of 

Willing Carriers Reduces 

Competition for EAS 

Routes 

As the pool of carriers willing to provide EAS service declines, 

competition for EAS routes has also declined. For example, of the 37 

routes that DOT awarded after three EAS carriers in 2008 ceased 

operations, 20 were awarded without competition, including 7 that were 

awarded to the one viable bidder remaining after the only other bidder 

went out of business. However, DOT officials informed us that their 

sealed-bid process prevents carriers from knowing whether there are 

competing bids from other carriers. They also indicated that they can 

reject bids that they believe are too high, and they can negotiate with the 

carrier. For instance, the officials cited a recent example of one carrier’s 

subsidy request of approximately $2.3 million being negotiated down to 

about $1.6 million. Nevertheless, a declining number of carriers willing to 

provide EAS service can reduce the level of competition among carriers 

for EAS routes. 

The Continued 

Urbanization of the United 

States and Changing 

Characteristics of the 

Airline Industry Contribute 

to Low Ridership of EAS 

Flights 

The viability of EAS routes also depends on the number of passengers that 

take EAS flights. According to DOT data, some EAS routes do not carry 

many passengers, creating a financial challenge for the carriers attempting 

to serve these communities. During fiscal year 2008, the average load 

factor—the percentage of available seats filled by paying passengers—was 

37 percent across all EAS flights. By comparison, the average load factor 

for unsubsidized commercial flights nationwide has averaged about 80 

percent in recent years. Two factors may contribute to the lack of 

passenger traffic on EAS flights. First, the EAS program has always served 

areas with limited population, but demographic shifts in the last 30 years 

may have reduced the population of some EAS communities, further 

Page 19 GAO-09-753 National Transportation System
 

limiting the potential passenger base for the local airport. Second, the EAS 

program loses potential passengers and fare revenue when low fares or 

more convenient air service schedules at nearby larger airports encourage 

passengers to bypass EAS service at their local airport in favor of driving 

or taking other transportation to the nearby airport. 

A significant degree of urbanization occurred throughout the 20th century 

as people moved out of rural areas and into cities and suburbs. Although 

much of this migration happened early and in the middle of the century, 

the trend has continued. Geographic areas, especially in the Midwest and 

Great Plains states, lost population between 1980 and 2007, as illustrated 

in figure 6. As a result, certain areas of the country are less densely 

populated than they were 30 years ago when Congress initiated the EAS 

program. Accordingly, some EAS communities’ reduction in ridership may 

be attributable, in part, to a smaller population base. 

Continued Urbanization of the 

United States May Lead to 

Reduced Passenger Ridership 

in Some EAS Markets 

Page 20 GAO-09-753 National Transportation System
 

Figure 6: Changes in Population Distribution, 1980–2007 

Increased 100 percent or more

Increased less than 100 percent

Declined

Source: GAO’s analysis of Census data.

Percentage Change in Population 1980–2007

Airports generally attract passengers from the surrounding population. 

However, people who live near smaller airports often choose to either 

drive to their destination or use larger airports that are farther away than 

their local airport. This phenomenon is typically referred to as “leakage.” 

Surveys of passengers as well as travel agents in communities served by 

small airports suggest that leakage can be widespread. For example, a 

travel agent survey in Arizona estimated that the small airports in that 

state often suffer significant leakage, in some cases as much as 90 

percent.33 Another study we conducted found that EAS airports often 

Relatively High EAS Fares, 

Low-Cost Alternatives, and 

Inconveniences Associated 

with EAS Flights Contribute to 

Low EAS Ridership 

 

33Arizona DOT, Aeronautics Division, Arizona Air Service Study (August 1999). 

Page 21 GAO-09-753 National Transportation System
 

serve less than 10 percent of the local passenger traffic,34 and that leakag

is a significant factor.

e 

) 

. 

 

35 Moreover, it appears that some people may be 

willing to drive considerable distances—more than 150 miles—to get to a

larger airport. The loss of passengers from an EAS route reduces the 

carrier’s fare revenues, while increasing the average per-passenger subsidy

for that EAS service. Therefore, significant passenger leakage can lead to 

(1) the carrier seeking a larger subsidy from DOT, (2) the community 

losing service if the per-passenger subsidy rises above the $200 cap, or (3

the route becoming so costly for the carrier that it chooses to file a notice

of intent to terminate service

Certain key factors appear to underlie the propensity of travelers to 

bypass small airports in favor of driving to larger airports. 

• Fares for EAS flights are generally high, relative to fares on 

comparable unsubsidized flights. We analyzed calendar year 2007 fares 

on routes involving EAS airports and compared these fares to the fares for 

routes of similar distances involving only non-EAS airports. We found that 

fares for EAS routes tend to be considerably higher—on average about 50 

percent higher—than fares for similarly distanced non-EAS routes. Our 

analysis did not attempt to identify reasons for the difference in fares 

between EAS and unsubsidized flights, but likely factors that could include 

the number of airlines serving the route, the number of passengers, and 

the portion of passengers paying the generally higher business fares on 

that route. Whatever the cause, relatively high fares for EAS flights can 

make those flights less attractive, compared to the alternative of driving to 

another airport. Studies of the use of airports in small communities have 

generally found that passengers may drive to nearby larger airports to 

obtain lower fares rather than use EAS service.36

34GAO, Commercial Aviation: Issues Regarding Federal Assistance for Enhancing Air 

Service to Small Communities, GAO-03-540T (Washington, D.C.: Mar. 11, 2003). 

35Specifically, over half of 207 small community airport officials we surveyed believed that 

passenger leakage occurred to a great or very great extent. GAO, Commercial Aviation: 

Air Service Trends at Small Communities Since October 2000, GAO-02-432 (Washington, 

D.C.: Mar. 29, 2002). 

36Arizona DOT, cited previously. Also, Pennsylvania DOT, Strengthening the Essential Air 

Service Program—A Pennsylvania Perspective, February, 2007. Also, Zhang, Yunlong; and 

Xie, Yuanchang, Small Community Airport Choice Behavior Analysis: A Case Study of 

GTR, Journal of Air Transportation Management, 11, 2006. 

Page 22 GAO-09-753 National Transportation System
 

• The growth of low-cost carriers has created alternatives to EAS 

service. Fifteen of 18 experts on our panel cited the expansion of low-cost 

carriers as one of the biggest challenges facing EAS providers, and 9 of 

these panelists cited low-cost carrier expansion as the most important 

challenge to EAS providers. In the past decade, low-cost carriers have 

considerably expanded their networks; these carriers’ share of domestic 

airline capacity increased from 20 percent in 2000 to 29 percent in 2007. By 

2007, low-cost carriers were serving virtually every large and medium-hub 

airport in the country as well as half of the small hubs. As low-cost carriers 

have extended service to more airports around the country, they provide 

more alternatives for community residents who can drive or take other 

transportation to other airports to get lower air fares offered by these 

carriers. Many industry stakeholders have said, and a previous GAO 

study37 has found, that community residents who reside near an EAS 

airport drive to other airports to obtain lower airfares, such as those t

low-cost carrie

hat 

rs offer. 

 

• Larger airports tend to offer better service than that available at 

EAS airports. Larger airports are generally more attractive to travelers 

than small airports served by EAS flights because they offer more frequent 

flights and more nonstop destinations. EAS communities receive at least 

the required two daily round-trip flights, 6 days per week—although some 

communities receive more. Still, most EAS routes connect a community to 

a single airport. Such limited service may be too inconvenient to meet the 

needs of time-sensitive business travelers. Studies have found that a key 

reason passengers avoid small airports is the more frequent flight offerings 

at larger airports, which can be more convenient for travelers.38 So, if 

driving to a larger airport is feasible, a traveler from a community may 

choose that option to get a nonstop flight to his or her destination, instead 

of taking an EAS flight from the local community airport. 

• Difficulties in making useful connections at the hub airports EAS 

carriers serve also discourage potential EAS passengers. For most 

EAS passengers, the hub airport where their EAS flight lands is not the 

end of their trip. Typically, EAS passengers need to transfer to a 

connecting flight to take them to their final destination. If the EAS flight 

37GAO, Commercial Aviation: Factors Affecting Efforts to Improve Air Service at Small 

Community Airports, GAO-03-330 (Washington, D.C.: Jan. 17, 2003). 

38Pennsylvania DOT, cited previously. Also, Hewings, Geoffrey; Wiedemann, Randal; and 

Reynolds-Feighan, Aisling; Economic Evaluation of the Impact of Air Service on Small 

Metropolitan and Rural Communities, conducted for the U.S. DOT June 20, 2000. 

Page 23 GAO-09-753 National Transportation System
 

takes passengers out of their way and increases their trip time, they may 

seek alternative travel options. Even if the EAS flight takes them in the 

direction of their final destination, limited EAS flight schedules may 

provide poor connection options. A representative of an airport in Iowa 

served by EAS-subsidized flights to Kansas City said it is hard to get 

business people to use the EAS flights because the flights often don’t 

match up well with the timing of connecting flights at Kansas City, 

resulting in long waiting times there. These problems promote passenger 

leakage away from EAS flights, when potential EAS passengers decide that 

traveling directly to larger airports is more practical. The problem is 

exacerbated as major carriers cut back their flights at the hub airports that 

are EAS destinations. For example, according to an official of one EAS 

carrier, connecting seats on flights out of two of their destination airports 

have decreased, reducing options for connecting flights, making the 

carrier’s EAS service to these airports less practical for passengers. As a 

result, the official said the carrier’s revenue on the routes serving these 

airports has declined significantly because potential passengers have 

decided to use other transportation to travel to a larger airport. 

• Problems with EAS service reliability are another deterrent to 

using EAS service. Five of the seven representatives of EAS-served small 

airports who responded to our questions noted that the reliability of EAS 

service was a significant concern. According to one of these airport 

representatives, delays, cancellations, and route and schedule changes are 

commonplace in most EAS communities. Another airport representative 

noted that reliability of air service may be even more important at small 

airports than at larger airports, because a cancelled or delayed EAS flight 

leaves passengers with no other options. Some experts we spoke with 

indicated that this is a particular disincentive to business travelers, who 

may choose to drive to a larger airport. 

As we noted in our recent report on the financial health of the airline 

industry,39 the current economic recession is contributing to decreased 

industry-wide air travel. Beginning in the second quarter of 2008, 

passenger traffic began to decline, when compared with the same quarter 

in the prior year. By the third and fourth quarter of 2008, traffic fell off 

more significantly, and airlines reduced capacity to maintain their load 

factors—which would not be an option for EAS carriers, because these 

carriers cannot reduce service below the minimum level required by the 

Current Economic Conditions 

Are Also Decreasing Demand 

for Air Travel 

 

39GAO, Commercial Aviation: Airline Industry Contraction Due to Volatile Fuel Prices 

and Falling Demand Affects Airports, Passengers, and Federal Government Revenues, 

GAO-09-393 (Washington, D.C.: Apr. 21, 2009). 

Page 24 GAO-09-753 National Transportation System
 

program. The downward trend appears to be continuing, as industry 

demand for the first two quarters of 2009 was less than was expected as of 

the beginning of the year. Indications are that the economy also affects 

carriers providing EAS service. Reported passenger enplanements for the 

first quarter of 2009 for one EAS carrier are down about 26 percent from 

the same period 1 year ago, and the carrier’s load factors declined from 46 

percent to 32 percent for that same period.40

Options for Modifying 

the EAS Program and 

Instituting a Multimodal Approach to 

Community 

Transportation 

Changes to Certain EAS 

Program Requirements 

Could Help Carriers 

Operate More Effectively 

and Potentially Reduce 

Program Costs 

Congress and others have been aware of the increasing difficulty EAS 

carriers face in providing service to communities. Congress, previous 

administrations, and GAO have proposed options to change the EAS 

program that might help address some of the program requirements that 

limit the flexibility of carriers providing EAS service or potentially 

increase costs of providing service—leading to carriers requiring higher 

subsidies from DOT. For example, DOT has proposed a number of options, 

but they have not been included in authorization or appropriations 

legislation. In addition, the House of Representatives’ proposal for 

reauthorizing FAA (H.R. 915) includes several options that could alter 

DOT’s management of the EAS program and possibly make program 

participation more attractive to carriers. This proposal is not yet through 

the legislative process. We also have described a number of similar options 

that could promote efficiencies in the EAS program. Again, none of these 

options have been adopted. Table 1 summarizes some of the key options 

that have been proposed. 

 

40Statistics cited represent the carrier’s total operations, not only EAS flights. 

Page 25 GAO-09-753 National Transportation System
 

Table 1: Potential Options to Revise the Essential Air Service Program 

Option (source) Description 

Allow carriers more flexibility for type of aircraft and service frequency 

Better matching air service capacity with community needs. 

(Previously proposed in DOT FY 2009 budget request, and in 

prior GAO reports) 

Better matching air service capacity with community needs, by 

allowing the use of smaller aircraft, or allowing less frequent flights. 

Award long-term EAS agreements, incorporate financial incentives, or allow agreements to be renegotiated 

Award long-term EAS agreements. (Section 404 – H.R. 915, 

FAA Reauthorization) 

DOT may execute long-term EAS agreements, to encourage an air 

carrier to provide air service to an eligible place, if in the public 

interest. 

Incorporate financial incentives into EAS agreements. (Section 

404 – H.R. 915, FAA Reauthorization) 

DOT may encourage carriers to improve EAS service by including 

financial incentives for meeting specified performance goals for 

factors such as on-time performance, reducing cancellations, 

establishing reasonable fares and convenient connections; and 

increasing marketing efforts. 

Renegotiation of EAS agreements. (Section 417 – H.R. 915, 

FAA Reauthorization) 

Subject to the availability of funds, the Secretary may renegotiate 

agreements to increase compensation to carriers for increased 

aviation fuel costs. 

Increase subsidy cap. (Section 413 – H.R. 915, FAA 

Reauthorization) 

The $200 subsidy cap to be increased by an amount necessary to 

account for the increase, if any, in the cost of aviation fuel in the 24 

months preceding enactment. 

Consolidate EAS flights at a single regional airport 

Consolidate EAS service at regional airports. (Previously 

proposed in DOT FY 2009 budget request, and in prior GAO 

reports) 

Consolidating EAS service at multiple nearby airports into one 

regional airport, where practical, to provide a larger passenger base 

for more effective service. 

Focus EAS assistance on most remote communities 

Targeting EAS service to the most remote communities. (GAO 

report) 

Increasing the highway distance criteria between EAS-eligible 

communities and the nearest qualifying hub airport, and expanding 

the definition of qualifying nearby airports to include small hubs. 

Targeting EAS service to the most remote communities 

(Previously proposed in DOT FY 2009 budget request) 

Ranking EAS-subsidized communities in order of decreasing driving 

distance to their nearest large- or medium-hub airport, and funding 

communities starting with the most isolated, and continuing in that 

order, until funding is exhausted. 

Capping EAS program eligibility as of a specified date 

Limit program size to communities currently receiving EAS 

subsidies. (Previously proposed by DOT officials in 2007 

testimony) 

The communities eligible for subsidy would be limited to those 

receiving subsidy as of a given date. 

Sources: Indicated in Option column above. 

Each of the proposed options has potential advantages and disadvantages. 

Some options would be beneficial in certain circumstances, but not for all 

communities or all parts of the country. Further, not all stakeholders will 

likely agree on which options should be implemented, especially when 

different options produce different beneficiaries. Finally, different options 

will have different impact on federal program costs—some likely 

Page 26 GAO-09-753 National Transportation System
 

increasing total program costs, while others might decrease or limit 

program costs. 

The EAS program’s current statutory minimum service requirements—

such as providing service with aircraft of at least 15-seats—may add to the 

cost of providing EAS service as discussed previously. Fifteen of the 17 

members of our expert panel who addressed the issue of aircraft size 

indicated that giving carriers more flexibility to use smaller aircraft would 

make the EAS program more effective. Currently, communities entitled to 

15-seat or larger aircraft can have EAS service with smaller aircraft only 

when they waive their rights to the larger aircraft. According to industry 

stakeholders, some communities are interested in having service from 

larger, at least 15-seat, planes because it is what the law provides for as 

well as for reasons including prestige and perceived concerns about 

comfort. 

Allow Carriers More Flexibility 

on Type of Aircraft 

Advantages 

Without this requirement for minimum aircraft size, a carrier would be 

allowed to “right size” or better match the services it provides with the 

communities’ demand, potentially reducing carrier operating costs as well 

as the subsidy needed from DOT and total federal program costs. Also, we 

previously reported that allowing carriers to provide EAS service with 

smaller aircraft could, on certain routes, be cost effective and better suit 

community needs.41 For example, officials of one EAS carrier which flies 

9-seat Cessna 402 aircraft told us that their lower operating costs allow 

them to provide more frequent flights and charge lower fares than the 

previous carriers which flew 19-seat aircraft on those same EAS routes. 

(See fig. 7 for an example of a 9-seat twin-engine aircraft.) 

 

41GAO, Options to Enhance the Long-term Viability of the Essential Air Service Program, 

GAO-02-997R (Washington, D.C.: Aug. 30, 2002). 

Page 27 GAO-09-753 National Transportation System
 

Figure 7: Example of a 9-seat Cessna 402 Aircraft 

Source: Cape Air.

This change has yielded significantly increased passenger ridership. 

According to the officials, in the first 10 months of service on one of their 

EAS routes, passenger ridership has gone up 143 percent compared to the 

previous EAS carrier’s ridership for a comparable period. In addition, the 

EAS program manager stated that if he could make one recommendation 

to Congress, he would suggest that Congress eliminate the 15-seat 

requirement because a few EAS carriers are providing good service with 

smaller aircraft. 

Disadvantages 

A disadvantage of this option is that smaller aircraft might not be suitable 

for all parts of the country. So, while this could be an option for certain 

routes, it would not fully replace the use of larger aircraft. For example, 

officials of the carrier that operates the 9-seat Cessna aircraft told us that 

the aircraft are not pressurized and may not be practical in mountainous 

areas in the west. Also, one airport representative believed that people 

would be more reluctant to fly on such smaller aircraft. In addition, these 

smaller aircraft operate under a different set of safety standards than the 

larger 19-seat turboprop aircraft most frequently used on EAS routes. 

According to industry representatives, this could negatively affect airlines 

that spent money to upgrade their aircraft to meet the safety standards 

now required for the 19-seat aircraft. An official of one EAS carrier that 

primarily flies 19-seat aircraft indicated that acquiring the infrastructure 

Page 28 GAO-09-753 National Transportation System
 

and personnel to support an additional type of aircraft would be a costly 

venture and not an option for their company. 

The EAS program’s current statutory minimum service requirements—-

such as providing at least twice-daily service, 6 days per week at EAS 

communities—potentially add to the cost of providing EAS service. Six of 

the 17 members of our expert panel who addressed this issue of service 

frequency believed such a change would make the program more effective. 

Allow Carriers More Flexibility 

on Service Frequency 

Advantages 

If a community is unable to generate enough passenger traffic to make 

twice daily, 6-day-per-week service viable for a carrier, even with an EAS 

subsidy, less frequent service might be more economically viable for the 

carrier. This change could also reduce the subsidy the carrier requires 

from DOT, assuming that passengers would adjust to the reduced 

schedule, and that overall passenger volume would not significantly 

decline due to increased passenger leakage. 

Disadvantages 

Some industry experts we spoke to believed that the current minimum 

level of service frequency is already so low that it is inconvenient for timesensitive business travelers, and encourages them to drive to other 

airports. One airport representative commented that service to one 

destination, twice a day, does not really fit the definition of “service.” 

Reducing service frequency might only further reduce a community’s 

support for EAS service by making that service less available and less 

useful. 

Some industry representatives have stated that the 2-year EAS agreements 

are too short, considering that carriers must lease aircraft for longer 

periods of time, such as five years. Five of 17 of our panel members 

identified extending the length of agreements as a way to make the 

program more effective. In addition, representatives of two airports served 

by EAS flights noted that carriers are not penalized for poor service—

carriers are still compensated when performance is poor or unreliable. 

Award Long-term EAS 

Agreements and Incorporate 

Financial Incentives 

Advantages 

Some industry representatives we contacted believed that authorizing 

DOT to award EAS agreements for longer than 2 years could better assure 

carriers that they will be able to stay in the program long enough to justify 

Page 29 GAO-09-753 National Transportation System
 

the commitments of financing and equipment that they need to effectively 

manage EAS service. This change may also attract more carriers willing to 

participate in the program. Financial incentives could also encourage 

better service by EAS carriers. In the view of one airport representative, 

carriers have spread themselves thin as they try to serve many subsidized 

communities, leading to undependable service, including late arrivals and 

departures. Incentives, or other means of linking subsidies to 

performance, can strengthen carriers’ commitment to providing reliable 

service. 

Disadvantages 

DOT and some communities have expressed concerns about lengthening 

the agreements because DOT would then have less frequent opportunity to 

remove carriers that are providing poor service—such as a large number 

of canceled or delayed flights. Instituting longer agreements would also 

reduce how often a route would be opened to competition, potentially 

reducing DOT’s ability to manage program costs. DOT officials also 

pointed out that they could award longer agreements under current 

legislation, but the program is still subject to annual appropriations. 

Carrier and industry officials also said they would like EAS agreements to 

allow DOT to adjust subsidy amounts in response to certain cost increases 

that occur during these agreements. For example, fuel costs increases in 

early 2008 affected EAS carriers’ operations. Program reauthorization 

legislation passed in 2003 allows DOT to adjust carrier compensation in 

response to increased costs, but DOT has chosen to not use this 

authority.42 Among our expert panel, 6 of the 17 individuals who addressed 

this issue believed allowing renegotiation of EAS agreements in response 

to rising costs would make the program more effective. Some industry 

representatives also believe the $200 per-passenger subsidy limit has been 

in effect for a long time and should be increased, even if only to reflect 

cost inflation. 

Allow Agreements to Be 

Renegotiated 

Advantages 

Allowing renegotiation of EAS agreements in response to rising costs 

would enable carriers to continue service when they are faced with rising 

costs rather than file a Notice of Termination which starts the process of 

 

42Vision 100—Century of Aviation Reauthorization Act, Pub. L. No. 108-176 (Dec. 12, 2003). 

Page 30 GAO-09-753 National Transportation System
 

reawarding the agreement to serve the community. Industry 

representatives have said that having to file a termination notice when 

cost increases make it uneconomic to continue service harms their 

relationship with the community and adds to the perception that service is 

unreliable. The proposal to allow an increase in the subsidy per passenger 

in response to fuel cost increases could allow some communities to retain 

EAS service—in times of rising fuel prices—which might otherwise lose it 

if carriers needed higher subsidies to continue that service. However, it 

could increase program costs faster than they would otherwise increase. 

Disadvantages 

Although authorized to do so, DOT generally has not adjusted carrier 

subsidies for current EAS agreements, because, according to DOT 

officials, they have limited program funds and reopening agreements could 

jeopardize funding to continue EAS service for all eligible communities 

that might qualify for it. A DOT official we spoke with also stated his belief 

that the $200 per-passenger subsidy cap has been effective as a primary 

tool to control costs. In addition, almost none of the experts on our panel 

believed that increasing the $200 per-passenger subsidy cap would make 

the EAS program more effective. 

We have also described an option of regionalization—essentially 

consolidating EAS service to and from a number of closely located EAS 

communities at a single airport.43 For example, there are currently 12 pairs 

of EAS communities that are within 60 miles of each other, and in 5 of 

these pairs the communities are within 50 miles of each other. The 

previous administration’s fiscal year 2009 budget request included 

language that would have supported regionalized air service. However this 

language was not incorporated in DOT’s appropriation, and was not 

included in the administration’s fiscal year 2010 budget request for DOT. 

Consolidate EAS Flights at 

Regional Airports 

Advantages 

In more sparsely populated areas, or areas where population has declined, 

this approach would focus EAS program support on one airport, and could 

increase the number of passengers using that airport, potentially making 

the service more viable. With more passengers using the airport, 

 

43GAO, Commercial Aviation: Programs and Options for the Federal Approach to 

Providing and Improving Air Service to Small Communities, GAO-06-398T (Washington, 

D.C.: Sept. 14, 2006). 

Page 31 GAO-09-753 National Transportation System
 

expanding service to include more flights, larger aircraft, or additional 

destinations, could be another potential benefit. 

Disadvantages 

Consolidating service at multiple airports into a single airport may not be 

initially popular with the communities that would lose EAS service at their 

local airport; passengers who did use the service provided at those 

airports would be inconvenienced. Also, some airport representatives and 

other experts said this option would depend on local circumstances, such 

as distance between the communities and driving conditions. However, if 

air service for several communities was consolidated at a single airport, in 

connection with support for ground transportation between those 

communities and the airport, it could increase the likelihood that 

communities would accept the consolidation. If this option is pursued, a 

nonpartisan commission may need to be established to make the difficult 

decisions—on an impartial basis—about where to provide EAS service. 

The existence of leakage demonstrates passengers’ willingness to bypass 

their local EAS service in favor of traveling to a larger airport that offers 

more flight options, more direct flights, and lower fares. Currently, to 

qualify for EAS service, a community must be at least 70 highway miles 

from the nearest medium- or large-hub airport. In previous reports we 

discussed the options of both increasing the 70-mile minimum qualifying 

distance, and including small hubs in this criterion.44 For instance, DOT 

information shows three communities with EAS service are within 50 

miles of a small-hub airport.45 As another approach to the same issue, 

DOT’s fiscal year 2009 budget request proposed ranking EAS-subsidized 

communities in order of decreasing driving distance to their nearest largeor medium-hub airport, and funding communities starting with the most 

isolated, and continuing in that order, until funding is exhausted, although 

this language was not incorporated in the fiscal year 2009 appropriation 

and not included in the fiscal year 2010 budget request. In addition, 13 of 

the 17 members of our expert panel who addressed this issue believed 

extending the qualifying distance from a hub airport above the current 70-

mile minimum would make the EAS program more effective. 

Focus EAS Service on the Most 

Remote Communities 

 

44GAO-06-398T; GAO-02-997R. 

45According to DOT officials, at each of these small hubs at least six carriers provide 

nonstop service to a minimum of 10 destinations, with between 38 and 46 weekday 

departures, primarily with jet aircraft. 

Page 32 GAO-09-753 National Transportation System
 

Advantages 

Proposals to extend the minimum qualifying distance from an EAS 

community to the nearest hub airport, or to otherwise focus EAS program 

funding on the more remote communities, would allow the EAS program 

to serve communities with relatively poor transportation access, while 

accommodating increasing costs and subsidies in an environment of 

limited program funding. 

Disadvantages 

Implementing one of these options would mean some communities that 

currently have EAS service would lose it, just as past changes in 

community eligibility requirements have led to some communities being 

dropped from the program. Also, some officials of community airports 

caution that basing eligibility on distance from a hub airport should 

consider local terrain and conditions—even the current 70 miles may not 

be a practical driving distance in mountain terrain, or where there is 

hazardous driving in winter. 

The cost of the EAS program and the number of communities served has 

grown substantially in recent years, with the potential for more 

communities seeking service in the near future. Essentially the 

communities eligible for subsidy would be limited to those receiving 

subsidy as of a given date. 

Capping Eligibility of Program 

as of a Specified Date 

Advantages 

Capping the program at the currently subsidized communities would help 

contain the program’s total costs. The stable size of the program would 

make it easier for DOT to manage the program and make funding the 

program more predictable, while not expelling any community currently 

receiving benefits under the program. 

Disadvantages 

If a community that is currently receiving unsubsidized commercial air 

service should lose that service, that community would not be able to get 

EAS subsidized service if this change was implemented. Since 

communities historically have come into and gone out of the program, the 

decisions about who would be eligible for subsidies would be based on the 

effective date selected for this change. 

Page 33 GAO-09-753 National Transportation System
 

Several of the proposed changes to the EAS program may help to address 

current concerns and enable the program to continue providing air service 

to communities. However, even with changes to the EAS program, some 

EAS communities would still have limited demand for the service, due to 

proximity to other airports or limited population. For such communities, 

other transportation modes might be more cost effective and practical 

than EAS service for connecting communities to the transportation 

network. Our expert panel, in addition to considering changes to the EAS 

program that would make it more effective, also considered the potential 

offered by more fundamental changes to the federal government’s 

approach to supporting intercity transportation for small communities. 

The 17 members on our panel who addressed this issue all believed that 

the EAS program needed substantive change to make it more effective in 

supporting small communities’ access to the national transportation 

network, and that a multimodal approach to provide financial assistance 

to small community transportation could potentially be more responsive 

to communities’ needs. 

A Multimodal Approach to 

Connecting Communities 

to the National 

Transportation Network Is 

Another Option 

GAO and others have also made proposals that would broaden the 

government’s approach to small community transportation to include 

other transportation modes. Proposals include support for other types of 

transportation besides scheduled air service and other approaches to 

financial assistance besides subsidies to carriers. For example, as part of 

the Vision 100-Century of Aviation Reauthorization Act in 2003, Congress 

authorized a number of changes to the EAS program, including the 

Community and Regional Choice programs, which allowed DOT to provide 

financial assistance directly to communities to obtain air taxi service,46 or 

pursue other transportation options. According to a DOT official, this 

program generated almost no interest from communities, perhaps because 

communities may believe that air service they have under current law is 

better than the alternatives. We have also proposed similar options that 

might enable the EAS program to provide less costly and more sustainable 

service, including better matching air service capacity with community 

needs by allowing the use of “on demand” service such as air taxis and 

changing the carrier subsidies into local grants, thus allowing communities 

more flexibility to determine how to the use the funds to best meet their 

needs. The previous administration’s fiscal year 2009 budget request also 

 

46Air taxi services provide on-demand regional air service, using small aircraft, and 

generally fly to and from small airports. For example, SATSAir, an air taxi service based in 

South Carolina, flies single engine, single pilot, three-passenger aircraft, and serves nine 

states in the Southeast. 

Page 34 GAO-09-753 National Transportation System
 

proposed modifying EAS program service requirements to allow program 

funds to be used for air taxi or charter service, or ground transportation. 

Congress did not enact any changes in response to this proposal. 

Most of the panel members thought that allowing the EAS program to fund 

other types of air service, such as air taxis, would make the program more 

effective. For communities with low passenger volume, this may be a more 

practical option than underutilized scheduled service. On-demand service 

could be more useful to some communities because flight departures 

would not be constrained by a limited schedule. Also, current EAS routes 

typically connect a community to just a single destination. On-demand 

service could still take community passengers to the hub, but it could also 

go to any airport within the range of the service’s aircraft. These features 

could make air service more useful to the community, increase demand, 

and make the operation more commercially viable. However, current EAS 

statutes require scheduled service by carriers and would have to be 

revised by Congress to accommodate air-taxi-type services. Additionally, 

current commercial air taxi services are relatively expensive. It may be 

hard to predict what such a service would cost under EAS, or the level of 

subsidy it would require, until it is tried. 

Alternatively, a community that cannot support EAS service within the 

subsidy limit might be better served through ground transportation. In 

many parts of the country, motorcoach companies and passenger rail 

already deliver passengers to large hub airports. For example, according 

to an American Bus Association official, motorcoach companies transport 

more than 2.5 million passengers annually from Maine, Vermont, and New 

Hampshire to Boston’s Logan Airport. The official said that about half of 

the communities currently in the EAS program are also served by 

motorcoach companies, which in some cases even provide community-tohub airport service that competes with EAS service. If a community 

cannot support air service even with an EAS subsidy, it may be able to 

support subsidized motorcoach or other ground transportation. 

Experts on our panel, as well as others with whom we spoke recognized 

that there will be difficulties if a multimodal approach to small community 

transportation is adopted. They noted that a multimodal approach to 

providing transportation assistance to small communities would likely 

face opposition from communities if they were to lose air service. In 

addition, it would create concerns about the potential source of funding 

because current DOT funding is largely “stove-piped” through funds that 

support—and are financed by—specific transportation modes. For 

example, federal funding for airports and aviation primarily comes from 

Page 35 GAO-09-753 National Transportation System
 

the Airport and Airway Trust Fund, which is funded by several aviationrelated excise taxes. Federal funding for highways is provided through the 

Highway Trust Fund which is supported by motor fuel and other vehiclerelated taxes. Experts on our panel and others said a multimodal approach 

can also result in different transportation modes “competing” for funds, as 

advocates for the various transportation modes may oppose any change 

that is seen as diverting funds dedicated to one transportation mode to 

support another. Taking a multimodal approach to small community 

transportation will require creative approaches to address these concerns. 

Finally, some of the experts in our panel expected that a true multimodal 

approach to support small community transportation would require more 

federal funding than the EAS program alone provides. 

Selecting Options for 

the EAS Program Is 

Difficult, but Tools 

Exist for Assessing 

the Options and 

Improving Program 

Evaluation 

Selecting Options to 

Implement Is Difficult and 

Depends on How Program 

Objectives Are Defined 

Over the years, Congress has made incremental changes to the program 

such as changing the eligibility criteria or funding; however the program’s 

approach remains little changed since it was implemented 30 years ago. 

Although Congress, the administration, GAO, and others have proposed 

potential changes to the EAS program, it is difficult for policymakers to 

determine which options to select, since different options for modifying 

the program might affect stakeholders such as airlines and community 

residents differently. For example, supporting increased use of smaller 

planes may increase the cost effectiveness of certain routes, but one 

industry association commented that this would penalize carriers who 

have made the investment in larger aircraft to satisfy current program 

requirements. In addition, as some of the panel experts and others 

recognize, these transportation decisions could become politicized. For 

example, a regional airport may make sense in certain geographic areas; 

however, no community would want to lose its local service, along with 

the assumed prestige and economic benefits to another community. 

Page 36 GAO-09-753 National Transportation System
 

Further, it is difficult to determine which option or suite of options to 

select, since stakeholders have different opinions on what the program is 

to achieve. When the program was established in 1978, it provided 

subsidized air service to communities that were receiving air service at the 

time and would have lost air service under deregulation, so in one sense, 

the program supports scheduled air service.47 However, the legislative 

history accompanying the Airline Deregulation Act also describes the 

program as supporting both connectivity to the national air transportation 

system and the growth and economic development of the communities 

served.48 These multiple program objectives make it difficult to assess 

which options to use. For example, if the objective is to continue 

providing air service to communities that were receiving air service at the 

time of deregulation, providing additional funding to cover expected cost 

increases and renegotiating contracts in response to cost increases like 

fuel prices could meet that objective. If the objective is to provide costeffective air service, options such as allowing more flexibility for type of 

aircraft and service frequency or establishing regional airports might be 

appropriate. Or if the objective is to provide access to the national 

transportation system, perhaps a multimodal approach or focusing on the 

most remote communities might be better options. 

Using GAO’s Reexamination Approach to 

Revisit the EAS Program’s 

Objectives Could Help 

Clarify the Extent to which 

Different Options Meet 

those Objectives 

Changes in the aviation industry and the nation’s financial situation over 

the past 30 years may make this an opportune time to revisit program 

objectives and evaluate design options for the program. In 2005, we 

reported that federal deficits portended an economically unsustainable 

situation in the long term, making it incumbent upon the federal 

government to periodically re-examine programs to assure they are able to 

meet current and future challenges.49 Certainly, the deficit picture has only 

grown more critical since then, as has the need for reviewing and updating 

federal programs to assure their continued effectiveness. In our report 4 

 

47DOT officials note that prior to deregulation, there was no guarantee of air service, and 

many communities lost air service under regulation. 

48See Legislative History of the Airline Deregulation Act of 1978, Committee Print 96-5, 

Committee on Public Works and Transportation, U.S. House of Representatives, May 1979. 

Review of Airline Deregulation and Sunset of the Civil Aeronautics Board (Essential Air 

Service Program and Small Community Air Service), Hearings before the Subcommittee 

on Aviation of the Committee on Public Works and Transportation, U.S. House of 

Representatives, August 16, 1983, and January 31 to February 1, 1984. 

49GAO, 21st Century Challenges: Reexamining the Base of the Federal Government, 

GAO-05-325SP (Washington, D.C.: February 2005) 

Page 37 GAO-09-753 National Transportation System
 

years ago, we developed several criteria designed to address whether 

existing programs are relevant to the challenges of the 21st century, and to 

support making tough choices in setting priorities. These criteria relate to 

(1) having well-defined goals with direct links to an identified federal 

interest and role, (2) defining and measuring program success, (3) 

targeting benefits, and (4) affordability and cost effectiveness. These 

criteria, which could be used to re-examine the EAS program, are 

summarized below and discussed in more detail in appendix III. 

The EAS program has multiple objectives, which are in some ways 

conflicting, contributing to a lack of clarity in the federal role. Revisiting 

the goals and objectives of the EAS program would help define the federal 

government’s role in the program, that is, what the federal government 

should be doing and how it should be doing it. For example, defining the 

EAS program’s objective as subsidizing scheduled commercial air service 

at communities that would not otherwise have air service, as the program 

has operated since it began, could lead to one program design and related 

performance measures addressing such factors as the number of 

communities with subsidized air service, the cost effectiveness of that 

service, and various measures for the quality of that service. However, 

identifying the objective of the program as providing rural and small 

communities with connectivity, including air service, to the national 

transportation network—which was also identified as an objective of the 

EAS program at the time it was enacted—could lead to defining a different 

set of options not limited to providing subsidized air service, but also 

considering multiple transportation modes. Supporting the broader 

objective of connectivity would also be consistent with DOT’s Strategic 

Plan, which identifies global connectivity as one of the agency’s strategic 

goals. 

EAS Program Goals and the 

Federal Government’s Role in 

Supporting These Goals and 

Objectives 

The performance measures that DOT has established for EAS relate to 

maintaining uninterrupted service at EAS-subsidized communities and the 

timeliness of processing agreements and making payments to carriers. 

Setting additional measurable targets for what the program is intended to 

accomplish would allow DOT to (1) assess the relative success of the 

program and (2) more effectively manage program resources toward 

achieving program goals or determine what level of resources are needed 

when the program is not achieving its objective. 

Defining and Measuring 

Program Success in Supporting 

DOT’s Strategic Goals 

Congress has modified eligibility criteria for the EAS program in the past. 

In 1978, the list of communities potentially eligible for EAS subsidized 

service was established. In 1994, Congress added the requirement that a 

community must be at least 70 miles from the nearest medium- or largeTargeting Program Benefits to 

Improve Program Results 

Page 38 GAO-09-753 National Transportation System
 

hub airport to qualify for EAS service. Examining the criteria again, given 

changes in population and the air service industry, may help target the 

benefits of the program to those communities that have the least access to 

the national transportation system. 

Analysis of the cost and affordability of EAS program can support 

decisions that may need to be made to address how and where to use 

existing program resources or if options to revise the program are 

warranted. Given the trend of increasing carrier subsidies and the 

potential for more communities seeking EAS subsidies if they lose their 

unsubsidized service, it is important for policymakers to assess whether 

the EAS program is affordable and financially sustainable over the long 

term, given known trends and risks. Consolidating service from two or 

more closely located EAS communities at a single airport is one option 

that could make service more cost effective. Another option that has the 

potential to improve cost effectiveness of EAS service for some 

communities would be to allow more latitude in determining the type of 

aircraft and flight schedules that would provide the level of service the 

community needs and can support. Finally, establishing a multimodal 

approach could provide cost-effective options for connecting people to the 

national transportation network. 

Analyzing Cost Effectiveness of 

Existing Program Options 

Analytical Tools Could 

Help Assess Program 

Demand and 

Transportation Options 

Since the EAS program’s basic design is 30 years old, policymakers may 

want to reconsider the characteristics of communities that are provided 

with federal transportation assistance. Reconsidering the design of federal 

programs—-such as the EAS program—requires a variety of information, 

and methods exist that can help develop such critical data. For example, 

Geographic Information Systems (GIS) analysis can be used to evaluate 

community access to transportation—both to air service and to other 

modes. In general, GIS applications are tools in which varied geographic 

information is compiled to enable analyses based on the relationship of 

one element, such as communities, to another element, in this case, modes 

of transportation. These tools have become critical in the field of 

transportation planning and management over the past 30 years. Such 

analyses can be used to evaluate transportation options, and help develop 

cost-of-service estimates. We analyzed the access that different groups of 

communities have to the various transportation modes by mapping those 

Geographic Information 

Systems Analysis 

Page 39 GAO-09-753 National Transportation System
 

communities along with the availability of the transportation modes. The 

goal was to take a fresh look at community access to transportation 

networks in the geographic context that exists today—a less rural society 

and potentially different transportation options than existed 30 years ago 

when the EAS program was conceived. 

The goal of our analysis is to use information on community 

demographics, access to transportation modes, and other relevant factors 

to illustrate how these key factors could be considered in developing an 

approach to ensuring access to air service or other modes of 

transportation. We examined the proximity of the selected communities—

community selection depended on community size and distance from 

medium- or large-hub airports—to transportation modes. We selected 

communities that had a population of between 10,000 and 500,000 people 

and that were at least 90 miles from the nearest medium- or large-hub 

airport. It would have been possible to select different sized communities 

or those that were either closer or farther from a medium or large hub. For 

selected communities, proximity to various types of airports, passenger 

rail stations, and entry ramps onto major highways were considered. This 

enabled comparisons across the communities as to their relative access to 

varied transportation modes. In appendix IV we provide outcomes of the 

analyses we performed to illustrate how GIS analysis can be used to reevaluate small community transportation options. This type of analysis 

might help determine the impact of the option to focus EAS assistance on 

communities that are most distant from alternative hub airports. 

Also, DOT’s Bureau of Transportation Statistics has taken steps to identify 

the intermodal connectivity of the population of the United States. In 2005, 

it published work showing that in 2003 about 93 percent of the rural 

residents lived within what DOT determined to be a reasonable coverage 

area of at least one of the four (air, bus, rail, and ferry) intercity public 

transportation modes.50 They acknowledge that this access may have 

diminished because of a recent reduction of Greyhound bus terminals and 

a portion of an Amtrak line. To get an even better idea of how connected 

the country is, DOT is continuing to work on an intermodal passenger 

connectivity project that involves cataloging and geographically plotting 

all transportation facilities in the United States and indicating what modes 

serve these facilities to develop a database of this information. While this 

 

50DOT, “Scheduled Intercity Transportation: Rural Service Areas in the United States,” June 

2005. 

Page 40 GAO-09-753 National Transportation System
 

is an ongoing project, data DOT has available could provide an additional 

source of information with which to evaluate the extent to which certain 

communities are connected to the national transportation network. 

In addition to GIS analysis, the tools and methods of benefit-cost analyses 

can be used to provide information on economic factors that may be 

useful in evaluating options. The cost of providing subsidized service to 

communities may vary considerably depending on the communities’ 

location or the type of service provided. Developing data to better 

understand these tradeoffs would help policymakers design the most 

appropriate program for the current circumstances. For example, 

estimates of program costs across various alternative modes and the value 

provided to communities for these services could help to ensure that 

programs are designed to use funds in the most beneficial way. 

Specifically, generating information on the expected demand for 

transportation services from communities could help stakeholders better 

understand the value gained by citizens from having access to service 

across various modes. 

Benefit-Cost Analyses 

Expanded Performance 

Measures Would Enhance 

DOT’s Ability to Evaluate 

Program Effectiveness 

The Government Performance and Results Act of 1993 requires executive 

agencies to develop a long-term strategic plan, prepare annual 

performance plans, and measure progress toward the achievement of the 

goals described in the plans. The annual performance plans should 

establish the connections between the long-term goals outlined in the 

agency’s strategic plan and the day-to-day activities of managers and staff. 

In addition, the goals and measures in the plan should address program 

results and how programs help the agency progress toward their strategic 

goals. 

EAS program performance is difficult to assess beyond providing air 

service to eligible communities because DOT does not have performance 

measures that demonstrate the extent to which the program is 

contributing toward DOT’s strategic goals of connectivity or congestion 

reduction—the strategic goal where the EAS program is located. Further, 

the Office of Management and Budget most recently evaluated the EAS 

program under its Program Assessment Rating Tool in 2006 and found the 

program does not have enough long-term performance measures that 

focus on outcomes and meaningfully reflect the purpose of the program. 

The EAS program’s current annual performance measures include one 

long-term measure that addresses program performance in a specific 

way—maintaining continuous air service at 98 percent of eligible 

communities. Other measures relate to administrative activities, including: 

Page 41 GAO-09-753 National Transportation System
 

(1) the percentage of renewal agreements that are established before the 

existing agreement expires, (2) the percentage of new agreements 

processed within 160 days of carriers’ notices to suspend services, and (3) 

the percentage of payments to carriers that are processed within 15 

business days. In 2007, the most recent year DOT published information 

on its performance in these areas, DOT exceeded its goals for the 

percentage of new agreements processed within 160 days and renewal 

agreements established before the existing agreement expires. DOT nearly 

met its goal for processing payments within 15 business days, and did not 

meet its goal for maintaining continuous air service at 98 percent of 

eligible, subsidized communities. DOT’s single long-term performance 

measure—maintaining continuous air service at 98 percent of eligible 

communities—- reflects an important aspect of program operations. But 

additional performance measures, addressing other aspects of program 

performance, could provide a broader perspective on how the EAS 

program contributes to DOT’s strategic goals. 

For many communities, the EAS program provides a valuable connection 

to the national transportation network. Many EAS routes carry 10,000 or 

more passengers per year. However, low passenger volume and high 

subsidies remain the norm for many EAS communities. Changes in the air 

service industry, including the growth of air travel alternatives provided by 

low-cost carriers, have changed the environment in which the EAS 

program operates. However, some legislative EAS program requirements, 

and the growing cost to operate aircraft for EAS service, contribute to the 

program’s inability to maintain service to EAS communities. Further, rural 

population shifts since deregulation, and continuing passenger leakage 

away from small airports with EAS service combine to limit passenger 

ridership on EAS flights. These factors contribute to the continuing 

financial strain on the EAS program which brings its long-term viability 

into question. 

Conclusions 

A re-examination of the EAS program, assessing options to make the 

program more sustainable and effective, and the development of 

performance measures to monitor program performance, may be 

warranted. Many options to help address the problems and limitations the 

current program faces exist. However, making these decisions is difficult; 

and Congress has yet to implement any of these options. These decisions 

are difficult because no one option may work for all communities. Options 

to change the program requirements might be necessary to sustain EAS. 

Further, in some locations it might be beneficial to study air taxi and 

Page 42 GAO-09-753 National Transportation System
 

multi-modal approaches to ensuring small and rural communities are 

connected to the national transportation network. 

Finally, if decisions are reached to revise the program design, steps should 

be taken to implement and monitor the program. For example, if the 

program design is to be revised the legislation governing the program 

would need to be revised accordingly. In addition, additional performance 

measures to evaluate the program may need to be developed. 

In light of developments related to population shifts, the aviation industry, 

and the national transportation infrastructure, Congress should consider 

re-examining the program’s objectives and related statutory requirements 

and seek information from DOT as needed to support this effort. Such a reexamination could include (1) consideration of the rationale behind 

existing statutory requirements, such as those for 15-seat, 2-engine, 2-pilot 

aircraft in EAS service; (2) the possibility of providing greater flexibility as 

to plane size, frequency of service, eligible communities, or regionalization 

of service; and (3) the possibility of assessing multimodal solutions for 

communities. 

Matters for 

Congressional 

Consideration 

We are recommending that the Secretary of Transportation Recommendations for 

Executive Action 1. Evaluate the reasonableness of 

• providing transportation service, whether through unscheduled air 

service or surface modes of transportation, when these alternatives 

might better serve communities than current scheduled EAS 

service, and 

• DOT’s current practices for carrier agreements, including the 2-year 

duration of agreements, and not renegotiating subsidy amounts in 

response to quantifiable cost increases. 

2. Once decisions are made about any changes to the EAS program, DOT 

should determine whether additional performance measures are 

needed to evaluate program outcomes. 

We provided a draft of this report to DOT for its review and comment. 

DOT provided technical comments in an e-mail message on July 6, 2009, 

which we incorporated into this report as appropriate. In reviewing our 

original recommendation calling for additional performance measures for 

Agency Comments 

Page 43 GAO-09-753 National Transportation System
 

the EAS program, DOT officials indicated that some performance 

measures were already in use, and said that they also monitor other 

performance data, such as passengers served. They acknowledged that 

additional performance measures would support operational 

improvement, and stated that they would determine those measures as 

needed. We believe the implementation of any changes to the EAS 

program—or how the EAS program is used to provide communities with 

access—which result from Congressional or DOT action would warrant 

consideration of additional performance measures. As a result of DOT’s 

comments and the possibility of changes to the program, we modified our 

original recommendation. DOT concurred with our revised 

recommendations. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 7 days from the 

report date. At that time, we will send copies to appropriate congressional 

committees, to the Secretary of Transportation, and to appropriate 

officials within the Office of the Secretary. We will also make copies 

available to others upon request, and the report will be available at no 

charge on the GAO Web site at www.gao.gov. 

If you have any questions about this report, please contact me at (202) 512-

2834 or at dillinghamg@gao.gov Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix V. 

erald L. Dillingham, Ph.D. 

Director, Physical Infrastructure Team 

G

Page 44 GAO-09-753 National Transportation System
Appendix I: Objectives, Scope and 

Methodology 

Page 45 GAO-09-753 

Appendix I: Objectives, Scope and 

Methodology 

To describe the status of the Essential Air Service (EAS) program, we 

reviewed Department of Transportation (DOT) data on the EAS program, 

DOT’s agreements with airlines to provide service, and financial data for 

the program and selected airlines. We also reviewed relevant studies and 

interviewed industry experts. Our review focused on communities within 

the 48 states of the continental United States that have received EAS 

subsidized service. This is because the requirements for communities in 

Alaska are different than for communities in other states. In addition, EAS 

subsidized service outside of the contiguous states are not representative 

of the program in the rest of the United States. 

We obtained DOT data that represented the characteristics and current 

status of the program at specific points in time in order to describe trends 

in EAS service. We obtained DOT data from 2003 through early 2009 on 

the number of communities served by the EAS program, the subsidies 

awarded airlines to serve these communities, and the passengers enplaned 

on EAS flights. We selected 2003 as our base year because that was the 

first full year DOT required carriers to file air traffic activity in a uniform 

reporting system.1

 DOT provided the information about EAS communities, 

associated subsidies, and carrier enplanements in a series of excel 

schedules. The schedules document EAS service only as of a specific dates 

and therefore do not represent a continuous picture of service provided 

under the EAS program. To assess the reliability of the community and 

subsidy information in the schedules, we selected a random sample of the 

subsidy award information in the schedules and traced the information 

back to the DOT order where DOT officially announced its agreement with 

a carrier to serve an EAS route. DOT issues its orders via its docket, 

accessible at www.regulations.gov. However, we could not assess the 

reliability of the carrier’s enplanement data in the schedules. To do so 

would have required a comprehensive review of DOT orders to identify the 

carrier serving each route, the destination hub, when the carrier initiated 

service on each route, and when the carrier either suspended or 

terminated service. Because the schedules do not represent a continuous 

picture of service provided under the EAS program, our review of DOT 

orders would also be incomplete. In addition, during the course of our 

review, we also found we could not develop trend information on 

passengers that board (enplane) subsidized EAS flights as well as the 

 

1

Effective October 1, 2002, DOT required all carriers to report their air traffic activity under 

the T100 reporting system. Prior to that date, small certificated and commuter carriers had 

reported their air traffic activity using the Form 298C. 

 National Transportation System 
Appendix I: Objectives, Scope and 

Methodology 

agreed-upon subsidies for those flights from available DOT data other than 

the information DOT provided in the schedules. 

We also obtained relevant financial data for the EAS program including 

appropriations and expenditures data. We reviewed relevant legislation to 

verify the appropriations information but did not have sufficient 

information to validate the expenditures data. We also obtained data 

documenting fuel use and cost in 2007 and 2008 for selected airlines from 

OAG BACK Aviation Solutions, a private contractor that provides online 

access to U.S. financial, operational, and passenger data with a querybased user interface. FAA does not require smaller airlines to file 

information on fuel use and cost, so we could only extract fuel data on 

certain larger airlines providing EAS service. We also compared fare data 

for routes involving EAS flights with fares on comparable unsubsidized 

routes, to assess how EAS fares compared to unsubsidized fares. 

We conducted a literature search to obtain research studies that examine 

the role of air service in the economic development of small communities 

and their connections to the national transportation network. Where 

applicable, the research and studies were reviewed by a GAO economist to 

determine that the studies were sufficiently reliable for our purposes. We 

also reviewed previous reports and studies of the EAS program including 

previous GAO, DOT, and other federal agency reports. We reviewed 

studies about the national transportation network and how rural 

communities connect to this network, reports on the rationale for the EAS 

program, and legislation that established and extended the program. We 

reviewed relevant regulations and legislation to obtain information on EAS 

program criteria and requirements for communities to be eligible for 

subsidized service under the EAS program. 

Finally, we conducted interviews with DOT officials, industry associations 

and consultants, airlines and community airports, local governments, and 

other relevant officials. 

To identify the factors affecting DOT’s ability to provide service to 

communities, we reviewed relevant literature, including previous GAO 

reports as well as other studies of the EAS program and air service to 

small communities. We identified the factors that limit the capacity of the 

EAS program to provide subsidized service to communities. We also 

examined the literature to identify the limitations inherent to small 

communities, aviation industry trends as well as the EAS program itself. 

We also analyzed data on fares charged for EAS flights. 

Page 46 GAO-09-753 National Transportation System
Appendix I: Objectives, Scope and 

Methodology 

We held a panel discussion attended by 19 experts on small community air 

service including airline officials, current and former EAS program 

administrators, economists, other transportation providers, and state and 

local officials. We discussed and surveyed these experts on the factors 

affecting the EAS program and options for providing connectivity to small 

communities across the country, including (1) the challenges facing air 

service to communities, (2) the role of the federal government in 

supporting communities’ access to the national transportation network, 

and (3) the federal government’s options for supporting small community 

transportation. We composed this panel of experts representing different 

types of stakeholders in the EAS program, including program officials. 

Thus, although individual panel members were not independent, the panel 

as a whole was balanced for our purposes. See appendix II for a summary 

of panel responses to questions we submitted to them, as well as a list of 

the panel participants. 

We reviewed Geographic Information Systems (GIS) and Bureau of the 

Census information as well as data from other sources to examine the 

extent to which the rural and small community population has shifted in 

the 30 years since the EAS program began. We identified areas where the 

population has grown as well as areas where the population has 

decreased. Further, we examined the extent to which selected rural areas 

are connected to the national transportation network. See appendix IV for 

further information. 

We identified options for improving the EAS program through a review of 

previous GAO reports, and discussions with officials from DOT and 

industry associations as well as industry consultants. We also identified 

options in proposed legislation that would affect the EAS program. We 

discussed these options with our expert panel, industry and program 

representatives, community officials, and other experts to obtain their 

views on the viability and feasibility of the options for providing assistance 

to remote communities and increasing their connectivity to the national 

transportation network. For example, a national association of airports 

sent questions we developed to seven of their member airports2

 about 

their experiences and views of the EAS program and forwarded their 

responses to us. 

 

2

Airports contacted were: Bradford (PA) Regional Airport, Cortez (CO) Municipal Airport, 

DuBois (PA) Regional Airport, Huron (SD) Regional Airport, Kirksville (MO) Regional 

Airport, Southern Vermont Regional Airport (Rutland, VT), and Shenandoah Valley 

Regional Airport (Staunton, VA). 

Page 47 GAO-09-753 National Transportation System
Appendix I: Objectives, Scope and 

Methodology 

To identify tools that may help DOT to re-examine and assess the 

performance of the EAS program, we reviewed literature that discussed 

options for improving the EAS program as well as GAO reports that 

discuss methods for re-examining federal programs in light of budget 

limitations. We reviewed previous GAO reports that discuss our reexamination framework to determine how such a framework could aid 

DOT in clarifying the strategic goals and options for the EAS program. We 

further examined DOT’s EAS program data and current performance 

measures in light of their usefulness for monitoring and managing the 

program. 

We conducted this performance audit from March 2008 through July 2009 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

Page 48 GAO-09-753 National Transportation System
Appendix II: Panelist Responses to GAO 

Questionnaire 

Page 49 GAO-09-753 

Table 2 summarizes responses provided by the members of our expert 

panel to the questionnaire we administered during the panel sessions. A 

listing of the panel members follows the summary of questionnaire 

responses. 

Table 2: Responses to GAO’s Questionnaire 

Part 1: Challenges facing air service to small communities—today and in the foreseeable future 

For each question, rank the three most significant factors, from 1 to 3. 

Number of panelists who ranked 

factor 

Question 1 2 3 

Total that Ranked 

as 1, 2, or 3

1) Which category of challenges is the most significant, in terms of its 

impact on carriers’ ability to provide air service under the EAS 

program? (19 panel members addressed this question) 

Challenges in serving the small community market. 3 8 0 11 

Challenges in the air service industry environment. 6 4 2 12

Challenges in the EAS program. 4 1 7 12

All of the above are equally important 6

None of the above are important 0

2) Which of the following aspects of providing and sustaining air 

service to small community markets present the biggest challenges? 

(19 panelists responded to this question)a

Small populations limit the market of potential passengers. 6 5 3 14 of 19

Limited community business activity limits the market of potential 

business passengers. 4 3 2 9 of 19

Rural and small community populations have shifted in the 30 years 

since deregulation—the EAS program may not be serving 

communities that have the greatest need for subsidized air service, 

in terms of other transportation options they may have. 6 3 3 12 of 19

EAS carriers may do insufficient marketing so that local residents 

are unaware of service. 0 3 2 5 of 19

“Leakage,” as small community residents bypass their local airports, 

and use other options for travel. 8 4 0 12 of 19

“Prop avoidance,” or travelers’ reluctance to fly in smaller turboprop 

aircraft that serve small airports. 0 3 2 5 of 19

Inadequate financial support, or other commitment, for EAS service 

from local government or the business community. 1 1 2 4 of 19

Inadequate federal funding for the EAS program. 1 2 1 4 of 19

Appendix II: Panelist Responses to GAO 

Questionnaire 

 National Transportation System 
Appendix II: Panelist Responses to GAO 

Questionnaire 

Number of panelists who ranked 

factor 

Question 1 2 3 

Total that Ranked 

as 1, 2, or 3

3) What changes in the air service industry environment since 

deregulation have been the biggest challenges to small community air 

service, including EAS service? (18 panel members addressed this 

question) 

Major carriers shifting to a hub-and-spoke route structure. 1 2 2 5 of 18

The expansion of low-cost carriers, creating more opportunities for 

small community residents to bypass their local airport in favor of 

lower fares at another airport. 9 4 2 15 of 18

Recent increases in fuel costs. 2 3 1 6 of 18

Decreasing availability of 19-seat turboprop aircraft used most often 

by EAS carriers. 2 1 3 6 of 18

EAS carriers’ difficulty in obtaining code share agreements with 

larger carriers that would allow passengers to book connecting 

flights on those carriers as part of the same trip. 1 2 1 4 of 18

Lack of interline arrangements with larger carriers that would allow 

passengers to check bags to their final destination. 1 2 1 4 of 18

Congestion at hub airports, with fewer slots available for small 

carriers. 2 2 3 7 of 18

The growth in business owned or leased aircraft, reducing the need 

for commercial business travel. 1 3 3 7 of 18

Increased post-9/11 security requirements at small airports. 0 3 1 4 of 18

4) What EAS program requirements represent the biggest challenges 

to providing and sustaining air service to small communities under the 

EAS program? (16 panel members addressed this question) 

The $200 per passenger subsidy cap (for communities less than 

210 miles from a medium or large airport). 0 1 1 2 of 16

The EAS program mandates using 15-seat or larger aircraft. 9 2 3 14 of 16

Minimum service requirements of two daily round trips, six days a 

week. 0 5 3 8 of 16

Two-year EAS agreements are too short. 3 2 2 7 of 16

No built-in agreement provisions for renegotiating subsidies to 

reflect rising costs (other than carriers filing a notice to terminate 

service, in order to negotiate a higher subsidy). 1 5 2 8 of 16

Insufficient profit margins (5 percent of operating expenses) allowed 

by the program. 1 1 2 4 of 16

Eligibility criteria—that a community must have had service at the 

time of deregulation—-has not changed since 1978. 2 3 3 8 of 16

a

Column totals exceed then number of panelists responding, because some respondents may have 

ranked more than one factor as “1” or “2,” etc. 

Page 50 GAO-09-753 National Transportation System
Appendix II: Panelist Responses to GAO 

Questionnaire 

Part 2: The role of the federal government in supporting small communities’ access to the national transportation network 

Question Number of Responses

1.) Should it be the federal government’s role to provide financial assistance to support small 

communities’ connection to the national transportation network? Check One. (17 panel members 

responded to this question) 

Yes 13

No 3

Uncertain 1

2) If the federal government should support small community transportation, what is the primary reason 

for doing so? Check one. (17 panel members responded to this question.) 

Supporting economic sustainability or growth in those communities. 5

Supporting those communities’ connection to the national transportation network. 4

Both of the above are equally important. 7

Neither of the above is important. 0

Other comment 1

3) Should there be performance goals, or measures of success, established for DOT to meet in 

carrying out transportation assistance programs, such as the EAS program? Check one. (17 panel 

members responded to this question.) 

Yes 15

No 2

4) What performance standards and measurable goals could be established for the EAS program? 

Check as many that apply. (16 panel members responded to this question.) 

Standards for access to the national transportation system. 13

Standards for community economic development. 9

Other 5

5) In general, do you believe the federal government should prioritize the relative transportation needs 

for communities, for the purpose of deciding which communities get federal funding? Check One. (16 

panel members responded to this question.) 

Yes 10

No 5

Other 1

6) Do you believe a system for assessing communities’ relative need for transportation, such as the 

methodology described by GAO, would be useful for targeting federal transportation assistance to 

small communities? Check One. (17 panel members responded to this question) 

Yes 14

No 2

Other 1

Page 51 GAO-09-753 National Transportation System
Appendix II: Panelist Responses to GAO 

Questionnaire 

Part 3: What are the federal government’s options for supporting small communities’ access to the national transportation 

network? 

Question 

Number of panelists who 

ranked factor 

Number of 

Responses 

1 2 3

Total that Ranked 

as 1, 2, or 3

1) Are there any EAS program criteria or requirements that should be 

revised to make the program more effective in supporting economic 

development and connectivity in the communities served? Check One. (17 

panel members responded to this question) 

Yes 17

No 0

2) If so, what changes might make the program more effective? Rank the 

three most significant, from 1 to 3. (17 panel members responded to this 

question) 

Increase the passenger subsidy cap from $200. 0 1 1 2 of 17

Award EAS agreements for longer time periods (e.g., 5 years). 2 1 2 5 of 17

Allow agreements to be renegotiated in response to rising costs. 1 2 3 6 of 17

Change criteria to focus program resources on more remote 

communities (i.e., increase the minimum 70-mile distance from a 

medium or large hub for a community to qualify). 

6 6 1 13 of 17

Give carriers more flexibility to use smaller aircraft. 8 3 4 15 of 17

Give carriers more flexibility to provide less frequent service. 0 2 4 6 of 17

Require carriers to commit funding to local marketing for EAS service. 0 0 3 3 of 17

Require carriers to have code share agreements with large carriers at 

destination hubs, to obtain an EAS agreement. 

1 0 2 3 of 17

Require carriers to have interline agreements with larger carriers, to 

obtain an EAS agreement. 

1 0 1 2 of 17

3) Does the EAS program need more substantive change or restructuring 

to make it more effective in supporting small communities’ access to the 

national transportation network? Check one. (17 panel members 

responded to this question) 

Yes 17

No 0

4) If so, what changes would make the program more effective? Rank the 

three most significant, from 1 to 3. (17 panel members responded to this 

question) 

Open the program to more communities by dropping the requirement 

that a community must have had air service at the time of deregulation in 

order to qualify for subsidized service. 

3 1 3 7 of 17

Allow the program to subsidize other types of air service, such as air taxi 

service, as an alternative to regularly scheduled air service. 

6 7 1 14 of 17

Give eligible communities the option of getting a grant, in lieu of EAS 

service, which can be used to obtain other transportation (e.g., 

subsidizing air taxi, or ground transportation). 

5 3 2 10 of 17

Page 52 GAO-09-753 National Transportation System
Appendix II: Panelist Responses to GAO 

Questionnaire 

Question 

Number of panelists who 

ranked factor 

Number of 

Responses 

1 2 3

Total that Ranked 

as 1, 2, or 3

Require local or state matching funding equal to some percentage of the 

federal funding. 

1 2 3 6 of 17

Base continued financial assistance upon meeting minimum 

performance standards, or other measures of success. 

2 0 2 4 of 17

Limit the number of years that a community can receive subsidized 

service under the program. 

1 3 2 6 of 17

5) What would be the benefits, if any, of the federal government taking a 

multi-modal approach to providing financial assistance to small community 

transportation? Check as many that apply. (17 panel members responded 

to this question) 

Potentially more responsive to individual community needs. 17

Potentially a better return in terms of useful services provided for the 

level of federal investment. 

14

May promote local and regional transportation planning. 14

Other 1

There would be no benefits. 0

6) What would be the costs or trade-offs, if any, of the federal government 

taking a multi-modal approach to providing financial assistance to small 

community transportation? Check as many that apply. (15 panel members 

responded to this question) 

Would require increased federal funding to be effective. 5

Funding may be diverted away from the EAS program. 6

Transportation modes will be competing against each other for funding; 

decisions on how funding is used will become increasingly politicized. 

7

Other 3

There would be no added costs or trade-offs. 4

Page 53 GAO-09-753 National Transportation System
Appendix II: Panelist Responses to GAO 

Questionnaire 

Panel Participants 

Ms. Debbie Alke 

Administrator 

Montana Department of Transportation, Aeronautics Division 

Mr. Randy Bennett 

Formerly with the U.S. Department of Transportation 

Mr. Gerald Bernstein 

Managing Director 

Stanford Transportation Group 

Mr. Dennis Devany 

Chief, Essential Air Service and Domestic Analysis Division 

U.S. Department of Transportation 

Mr. John Fischer 

Specialist in Transportation 

Congressional Research Service 

Mr. Drew Galloway 

National Railroad Passenger Association 

Mr. Steve Hanvey 

President and CEO 

SATS Air 

Mr. Clyde Hart 

Vice President for Government Affairs 

American Bus Association 

Dr. Andrew Isserman 

Professor of Urban and Regional Planning and 

Professor of Agricultural and Consumer Economics 

University of Illinois 

Ms. Tulinda Larsen 

formerly with OAG BACK Aviation Solutions 

Mr. David Lee 

Managing Director, Economics 

Air Transport Association 

Page 54 GAO-09-753 National Transportation System
Appendix II: Panelist Responses to GAO 

Questionnaire 

Mr. Henry Ogrodzinski 

President and CEO 

National Association of State Aviation Officials 

Dr. Clinton Oster, Jr. 

Professor and Associate Dean 

Indiana University 

Ms. Robin Phillips 

Senior Director of Policy 

American Bus Association 

Mr. Tim Rogers 

Airport Director 

Salina Airport Authority 

Mr. Andrew Steinberg 

Partner 

Jones Day 

Mr. Bill Swelbar 

Research Engineer 

International Center for Air Transportation 

Massachusetts Institute of Technology 

Mr. Doug Voss 

President 

Great Lakes Aviation 

Mr. Charlie Walsh 

Chairman 

Southeast Iowa Regional Airport Authority Board 

Page 55 GAO-09-753 National Transportation System
Appendix III: 21

Pr

st Century Questions for 

ogram Re-examination 

Page 56 GAO-09-753 

Appendix III: 21st Century Questions for 

Program Re-examination 

In 2005, we reported that federal deficits portended an economically 

unsustainable situation in the long term, making it incumbent upon the 

federal government to periodically re-examine programs to assure that 

they are able to meet current and future challenges.1

 Many current federal 

programs and policies were designed decades ago to respond to trends 

and challenges that existed at the time of their creation. Much has changed 

since then. Therefore, we developed criteria for policymakers to consider 

as they address emerging needs by weeding out programs and policies that 

are outdated and ineffective and updating existing programs that are still 

relevant. We framed the criteria as questions designed to address the 

legislative basis for the program, its purpose and continued relevance, its 

effectiveness in achieving goals and outcomes, its efficiency and targeting, 

its affordability, its sustainability, and its management. We used these 

criteria to generate specific 21st century questions about those programs 

and priorities already identified. The resultant 21st century questions 

illustrate the kinds of issues that a re-examination and review initiative 

needs to address. 

Relevance and Purpose 

of the Federal Role 

• Does it relate to an issue of nationwide interest? If so, is a federal role 

warranted based on the likely failure of private markets or state and local 

governments to address the underlying problem or concern? Does it 

encourage or discourage these other sectors from investing their own 

resources to address the problem? 

• Have there been significant changes in the country or the world that relate 

to the reason for initiating it? 

• If the answer to the last question is ‘yes,’ should the activity be changed or 

terminated, and if so, how? If the answer is unclear as to whether changes 

make it no longer necessary, then ask, when, if ever, will there no longer 

be a need for a federal role? In addition, ask, “Would we enact it the same 

way if we were starting over today?” Has it been subject to comprehensive 

review, reassessment, and re-prioritization by a qualified and independent 

entity? If so, when? Have there been significant changes since then? If so, 

is another review called for? 

 

1

GAO, 21st Century Challenges: Reexamining the Base of the Federal Government, 

GAO-05-325SP (February 2005). 

 National Transportation System 
Appendix III: 21st Century Questions for 

Program Re-examination 

• Is the current mission fully consistent with the initial or updated statutory 

mission (e.g., no significant mission creep or morphing)? Is the program, 

policy, function, or activity a direct result of specific legislation? 

Measuring Success • How does it measure success? Are the measures reasonable and 

consistent with the applicable statutory purpose? Are the measures 

outcome based, and are all applicable costs and benefits being 

considered? If not, what is being done to do so? 

• If there are outcome-based measures, how successful is it based on these 

measures? 

Targeting Benefits • Is it well targeted to those with the greatest needs and the least capacity to 

meet those needs? 

Affordability and Cost of 

Effectiveness 

• Is it affordable and financially sustainable over the longer term, given 

known cost trends, risks, and future fiscal imbalances? 

• Is it using the most cost-effective or net beneficial approaches when 

compared to other tools and program designs? 

• What would be the likely consequences of eliminating the program, policy, 

function, or activity? What would be the likely implications if its total 

funding was cut by 25 percent? 

When taken together, these questions can usefully illustrate the breadth of 

issues that can be addressed through a systematic re-examination process. 

Page 57 GAO-09-753 National Transportation System
Appendix IV: 

Analysis of S

A 

Geographic Information Systems

mall Community Transportation 

ccess

Page 58 GAO-09-753 

Appendix IV: Geographic Information 

Systems Analysis of Small Community 

Transportation Access 

This appendix provides an overview of the GIS analyses we conducted of 

community access to the transportation network. In this appendix we 

discuss (1) the motivation for the analysis, (2) some key societal and 

industry factors that have changed since deregulation, (3) how we 

generated the set of communities for examination, (4) how an index 

measuring of “access” was defined, and results for communities’ access to 

airports, Amtrak, and major roads. 

GIS Analysis Could Aid a 

Re-examination of 

Community Access to 

Transportation Network 

It has been approximately 30 years since the EAS program was developed 

as part of the deregulation of the airline in industry in 1978. The program 

had the particular goal of ensuring that communities that had commercial 

airline service in the regulated era retained that service even if the newly 

deregulated airlines chose not to provide service to some of those 

locations. Given that goal, the communities that were eligible for the 

program were essentially those that had had airline service at in 1978. 

Thirty years later much has changed in the industry and in the country. 

The country has experienced demographic shifts, automobiles are of 

better quality, and the airline industry has continually restructured itself. If 

the EAS program—or any program that promotes access to the national 

transportation network—is to be re-examined, consideration of these 

developments is warranted. The goal of our analysis is to use information 

on community demographics, access to transportation modes, and other 

relevant factors to provide illustrations of how these key factors could be 

considered in developing an approach to ensuring access to air service or 

other modes of transportation. Our intent is not to point to any particular 

program structure, but rather to illuminate the type of information that can 

be brought forth to help policymakers answer those questions. 

U.S. Settlement Patterns 

and Key Industry Factors 

Could be Considered in 

Re-examination of Subsidy 

Program 

Throughout the 20th century, a significant degree of urbanization occurred 

as people moved out of rural areas and into cities and their suburbs. 

Although much of this migration occurred during the early and middle 

parts of the 20th century, the trend has continued. Figure 8 illustrates how 

rural areas, especially in the Midwest and Great Plains states, lost 

population between 1980 and 2007. This migration left areas of the country 

less densely populated than they were 30 years ago when the EAS program 

was initiated. To the extent that the provision of unsubsidized commercial 

air service is a function of the size of the local market, information on the 

shifting settlement patterns might be a useful input into a re-examination 

of a transportation access program. 

 National Transportation System 
Appendix IV: Geographic Information Systems 

Analysis of Small Community Transportation 

Access 

Figure 8: Changes in Distribution of Population, 1980 to 2007 

Increased 100 percent or more

Increased less than 100 percent

Declined

Source: GAO’s analysis of Census data.

Percentage Change in Population 1980–2007

Along with demographic shifts, the airline industry has changed since 

deregulation. Airlines have continually restructured their route networks, 

fleet mix, and pricing structures. New airlines with varied business plans 

have entered the industry, some airlines have exited the industry 

(sometimes through bankruptcy), airlines have formed alliances, and the 

manner in which airlines meet in the marketplace and compete has been 

dynamic. One of the most significant elements of the industry’s 

development has been the entry and growth of low-cost carriers over the 

past decade. These carriers developed different route networks than the 

so-called “legacy” carriers, used different pricing structures, and generally 

charged lower fares. Evidence suggests that, to obtain lower fares, 

passengers are often willing to drive to a distant airport where a low-cost 

Page 59 GAO-09-753 National Transportation System
Appendix IV: Geographic Information Systems 

Analysis of Small Community Transportation 

Access 

carrier offers service. This availability may thus have created new travel 

options for residents of remote communities. 

Characterization of 

Community Access to 

Transportation Could Be 

Based on Demographic 

and Geographic 

Information 

As noted above, our goal was to evaluate current community access to air 

and other transportation modes. Here, we define access as the point at 

which the traveler begins her journey on an airplane, on an interstate 

highway, or on an intercity passenger train. Because travelers from any 

given community could be going anywhere in the world, we do not assess 

access relative to reaching any particular destination. That could be done, 

say with respect to travel to a major medial facility, and could be 

appropriate depending on how the transportation needs of a community 

are framed. Our intent here is to show, in the most general way, how 

geospatial analysis is a useful analytical tool for analyzing EAS or any 

other program that aims to provide access to the national transportation 

network. 

To allow comparison of communities’ access to transportation modes, we 

made a number of informed but ultimately arbitrary assumptions about 

what size communities to include and how to define access to commercial 

air service in terms of distance to an air embarkation point. An advantage 

of geospatial analysis is that these thresholds may be easily varied to 

determine the sensitivity of the results to different assumptions. The 

analysis we describe illustrates the potential for this approach to 

understanding access. 

Specifically, because we know that settlement patterns have shifted since 

the inception of the EAS program, we examine communities in a 

contemporary setting. In particular, we considered all urbanized areas—

based on the most recent Census information—in the lower 48 states; 

there are 3,569 urbanized areas. At deregulation in 1978, Congress was 

specific about which communities would be eligible for subsidies to 

ensure continuation of scheduled air service—the communities were 

those that had or were eligible for scheduled air service under the Civil 

Aeronautics Board’s regulatory regime when the industry was deregulated 

and airlines were given the ability to choose what routes they would fly. In 

today’s setting, the underlying concept of which communities should be 

ensured service might translate as a concern about the vulnerability of 

communities to loss of commercial air service or an inability of 

communities to attract commercial air service. 

So, for our analysis, we asked “Which communities are most likely to 

encounter difficulty attracting, retaining, or expanding air service?” We did 

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not consider those with fewer than 10,000 people based on the assumption 

that it would not be feasible, in terms of the federal budget or airline 

operating capacity, to extend service to many relatively small places. The 

remaining 1,284 communities, those with populations between 10,000 and 

less than 500,000, include 36 percent of all urbanized areas and account for 

about 25 percent of the U.S. population. 

Within this group of 1,284 communities, there are those that can be 

considered relatively close to an airport of considerable size, defined as a 

medium or large hub. While the EAS program uses a 70-mile criterion for 

that element of eligibility, we ran an analysis using 90 highway miles. This 

increase in distance was motivated by the general improvement of 

automobiles over the past 30 years. With this threshold in place the 

number of urbanized areas in our base-case analysis dropped to 727. 

Across the 727 communities in the group of interest (with population 

between 10,000 and less than 500,000 and more than 90 miles from a 

medium or large hub), there is variation in access to scheduled 

commercial air service. Some of these communities may be close to small 

air hubs or have some less frequent commercial service. Others may not 

have an airfield at all. However, because communities in this set are all 

distant from the busiest air hubs, their access to air transport is vulnerable 

to reductions or elimination of nearby commercial service or is precluded 

by their inability to retain or to attract service at all. Relative to other 

communities, then, their access to medium- and large-hub airports may be 

compromised by their remoteness. 

Community Access to 

Transportation Modes Can 

be Expressed by Means of 

an Index of Relative 

Access 

While the community group of interest has been defined with respect to 

access to air service, we want to describe the range of travel options 

available to travelers. So, we consider community access to the interstate 

highway system and to passenger rail service as well as airline travel. As 

with air service, access is defined in terms of the driving distance, distance 

to an on-ramp for interstate access and, for passenger rail, distance to an 

Amtrak passenger station or to a bus link to a passenger station. Interstate 

access may mean travel by car or by bus, but that distinction is not made 

in our analysis because we did not have ready access to bus schedules for 

the 727 communities. In addition, we did not make any distinctions 

regarding level of service, including time of day or frequency. For 

example, if Amtrak stops at a community at 3:00 am, this clearly impacts 

access, but we did not consider that limitation. Similarly, service at some 

medium hubs may not be considered very extensive in terms of the 

number of places one can travel to on a nonstop flight. 

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Geospatial analysis allows us to compute distances to access points for 

each community, and we can use those distances to measure and compare 

communities’ access to one or multiple modes. We constructed a set of 

simple indices that allow characterization of each community’s access to 

air, rail, and/or train service relative to the other communities. In our 

analysis, the denominator is the average distance to the transportation 

mode for the 727 communities. 

• For the highway index, the index value would be: 

the distance for community i to an interstate highway 

——————————————————————————————— x 100

average distance across communities to an interstate highway 

• For the passenger rail index, the index value would be: 

the distance for community i to an Amtrak station 

——————————————————————————————— x 100

average distance across communities to an Amtrak station 

• For the aviation index, the index value would be: 

the distance for community i to a medium or large hub airport 

——————————————————————————————— x 100

average distance across communities to a medium or large hub airport 

If a community has an index value of 100 for its access to air 

transportation, it means that its distance from a medium- or large-hub 

airport, among the communities evaluated, is average. A higher index 

value signifies a more remote community than average, and a lower index 

value signifies a community is nearer to that mode than average. Figure 9 

shows the 727 communities’ access to medium- or large-hub airports as 

measured by this index. Communities denoted with triangles are further 

from a medium- or large-hub airport than is average for the set of 

communities, and communities denoted with circles are closer to such an 

airport than is average for the set of communities. We found that the 

average distance from a medium- or large-hub airport was 173 miles. Of 

these 727 communities, 454 were within 173 miles and 273 were farther 

than 173 miles, some as much as 682 miles away. As can be seen, 

communities that are more remote than the average of 170 miles from air 

transportation are found mainly in the Intermountain West, the Plain 

states, the Mississippi Delta, and in Appalachia. Comparing this result with 

the map documenting shifts in population shows that these areas are also 

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Access 

the ones that generally experienced population declines between 1980 and 

2007. 

Figure 9: Access to Transportation: Air Transport Only 

Index of distance to medium/large hub

52–100 (454)

101– 395 (273)

Source: GAO’s analysis of DOT data.

Figures 10 and 11 show the same communities’ relative access to highways 

and passenger rail, as represented by index values. 

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Figure 10: Access to Transportation: Major Highway Access 

Source: GAO’s analysis of DOT data.

Index of distance to interstate highway

0–100 (469)

101–1,020 (258)

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Figure 11: Access to Transportation: Passenger Rail 

0–100 (432)

101– 441 (295)

Source: GAO’s analysis of DOT data.

Index of distance to passenger rail

Considering access to the interstate highway system (figure 10), for these 

727 communities, the average distance to an on-ramp is 33 miles. Sixty-five 

percent are within 33 miles (circles), with the other 35 percent (triangles) 

more than 33 miles away, and some as many as 335 miles away. Again, 

those farthest away from the interstates, in the Plains especially, are also 

areas that have experienced population loss. For access to passenger rail 

(figure 11), the patterns are similar to those for access to the interstate. 

To obtain a perspective on communities that are the most remote, for 

figure 12 the index is calculated to characterize access across modes. 

Equal weight is given to access across modes, but it is clearly possible to 

apply different weights to the separate modes’ index values, reflecting 

greater emphasis on access to one mode (say, air) versus another. Here 

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again, 60 percent of the 727 communities have better-than-average access 

to the transportation network (via any mode), while 40 percent are 

relatively remote. The fact that some communities’ index values are very 

large demonstrates the heterogeneity in access across the 727, suggesting 

very different degrees of remoteness even among communities that are 

distant from medium- or large-hub airports. Because both distance and 

population density matter in the provision of transportation services, this 

heterogeneity will figure importantly in weighing the costs and benefits of 

supporting or subsidizing access to the transportation network. 

Figure 12: Access to Transportation: All modes, Weighted Equally 

Index of distance to any mode

20–100 (446)

101–513 (281)

Source: GAO’s analysis of DOT data.

Our analysis identified 727 communities within a range of population of 

10,000 to less than 500,000 that are alike in that they do not have ready 

access to the nation’s busiest medium- and large-air hubs. We then 

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calculated index values that allowed us to characterize the extent of 

remoteness from interstate highways and passenger rail stops. Different 

criteria will produce different groupings of communities in terms of how 

connected they are to the national transportation system. Supplementing 

the information provided by the index values with knowledge about actual 

levels of air service (at small hubs or airfields) and about bus and rail 

service would provide a frame for considering transportation policy goals. 

One way this analysis can be useful in considering the EAS program 

specifically is to ask which of these 727 currently are served by EAS 

(defined as being located within 40 miles of an EAS airport). And, which 

EAS communities are not included among the 727, that is, how many EAS 

communities are in proximity to the nation’s busiest air hubs, or have 

fewer than 10,000 residents? Figure 13 shows that about 17 percent (123) 

of these communities have EAS service.1

 

1

These communities are within 40 miles of an airport that has EAS service, so the number 

differs slightly from communities that are provided service under EAS. 

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Figure 13: Access to Transportation: Current EAS Communities and Other Selected Communities’ Access to Medium- and 

Large-Hub Airports 

52–100 (392)

101–369 (212)

Source: GAO’s analysis of DOT data.

Communities with access to EAS (123)

Communities with access to EAS

Index of distance to medium/large hubs

Recognizing the changes in the structure of the airline industry, a 

community’s proximity to an airport served by a low-cost carrier might be 

another way of characterizing access to the air transport network. In 

Figure 14, we identify which of the 727 communities are within 150 driving 

miles of such an airport. Here, we find that 92 percent have access to lowcost carrier at airports outside their communities. 

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Figure 14: Access to Transportation: Communities with Access to Airports Served by Low-Cost Carriers 

Access to low cost carriers

Has access (671)

Does not have acess (56)

Source: GAO’s analysis of DOT data.

With respect to the EAS program as it exists today, our analysis suggests 

that there is heterogeneity across those communities that currently have 

EAS service in terms of size and distance to the nation’s busiest airports or 

airports served by low-cost carriers. And, it suggests that there are other 

communities whose relatively limited access to the air transport network 

might warrant consideration of alternatives for connection to the nation’s 

transportation network, whether air or road or rail. 

This type of analysis does not and cannot answer the policy question 

about what kind of access to a transportation network a remote 

community ought to have. Rather, it serves as a point of departure for 

tackling that question by characterizing the nature of access as it exists 

today. Geospatial findings can be supplemented by information on other 

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Access 

costs of travel (besides time) and also their benefits to evaluate tradeoffs 

of different levels of access. Here, access is measured in terms of driving

distance to a point of entry for a mode, which is a proxy for a traveler’s 

time. That time could be valued, and other costs, such as air or tra

fares to different destinations as well as gasoline prices could be 

calculated and compared. Beyond the perspective of the individual 

traveler, public and/or private sector costs of provision of service could

taken into account, as can preferences for the frequency and quality of 

transport services. However, because location figures as a key factor in

both costs and benefits of travel, geospa

in or bus 

 be 

tial analysis provides a useful 

frame for policy and program analysis. 

Page 70 GAO-09-753 National Transportation System
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 71 GAO-09-753 

Appendix V: GAO Contact and Staff 

Acknowledgments 

Dr. Gerald L. Dillingham, (202) 512-2834 or dillinghamg@gao.gov 

In addition to the person named above, Cathy Colwell, Assistant Director; 

Amy Abramowitz; Richard Brown; Colin Fallon; David Hooper; Don 

Kittler; Hannah Laufe; John Mingus; Susan Offutt; and Bonnie Pignatiello 

Leer made key contributions to this report. 

 National Transportation System 

GAO Contact 

Staff 

Acknowledgments 

(540168) 
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