MA'Y -29-2012 09: 59A FROM: HAGERSTOWt
·H,JASHINGTCI 2403 132281

Hagerstown Regional Airport 

### RichardA. Nenson Field 18434 Shownlter Road, Suite I**~** Hagerstown, Maryland 21742·1381 l.f: Telephone: 240..313-2777 1<1 FAX: 301-791·2590**.~..tit'** T0 : 912023667638 F'.l-"3**~v** Denfnnd Hnrd ofHenring call7-l-1 for Morylnnd Relay**R\C\\'.1.~"" ;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;liiiiiiiiiiiiiiiiiiiiiiliiiiiiiiiiliiiiiiiiiiii;;;;iiliiiiiiiiiiiiiiiiiiiiiliiiiiiiiii~iiiiiiiii=;;;;;;;;;;;;;;;iiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiii;;;;;;;;;;;iiiiiiiiiiiiiii**  May24, 2012



### Mr. Dennis J. DeVany, Chief

-- EAS & Domestic Analysis Division O:fficc ofAviation Analysis :

.**~ -:** **:::** :·**:· ~** 

- . , . J**~** •

... ... United States Department ofTrmlSportation 1200 NewJerseyAvenue, SE**~,** . -:-.:::.:.· - Washington, DC 20590 

### DearMr. DeVany:

We are writing in response to the Esse11tial Air Service (BAS) proposal that was summarized in your May 4, 2012 e-mail and recorded inthe Federal Document Management System (#25228). We also wish to take this opportunityto reiterate our appreciation ofthe EAS Program, its administrators and the funding it provides. In this difficult time, without this financial 

### support, our ability to assure access to the National AirTransportation system for the citizens of Hatcrstown, Washington County and the surrounding quad-state region through Hagerstown Rogional Airport (HGR or the Airport) would bechallenged. Having reviewed your SUlllirutl)' document, SunAirExpress, LLC's (d/b/a Sun Air) original proposal and having conducted a face to face meeting with Sun 

### Air representative, David 

### Hackett, we are once 

### again struck by

### the changing landscape oftheBAS program. Based on**tbe.~;~e** three contributing factors we offer the following comments:
Our understanding is that Sun Airhas submitted an inseparableproposal for Hagerstown, Maryland and Lancaster, 

### Pennsylvania offering daily passenger service on nine passenger Piper Chieftain aircraft to either Baltimore/Washington International Thurgood Marshall Airport 

## (Bwn or Washington 

### Dulles International 

### Airport (JAD), 

### with 24 nonstop round trips a week for Hagerstown and 30 nonstop round trips a week for Lancaster, each ofwhich has been 

### proposed at different annual subsidy rates. Ofthese two alternatives only Sun Air's "Service Option 2" describing daily service to and from Washington Dulles International Airport (lAD) would be acceptable to Hagerstown. Having said this, we have many concerns about Sun Air (Operator) and its proposed operation. 1) The Operatorlacks the necessary operating authorities from the:; U.S. Department of Transportation {DOT) and the Federal Aviation Administration (FAA) to provide daily 

### scheduled passenger operations. · 

### 2) 

### AB aresult the 

### Operator has no experience 

### in 

### providing daily scheduled passenger operations.MA\'-29-2012 09: 59A FROM: HAGERSTOWtH..JASHINGTO 2403132281

Dennis DeVany May 24,2012 Page 2 of3 TO: 91202366763E:

3) As we understand it, the Operator docs not presently have the aircraft necessary to provide this service. Without these, the condition ofaircraft interiors and exteriors is unknown. 4) At this time we understand that there is nQ commitment, verbally or otherwise, from BWI or lAD (or from their tenants) for the space necessaryfor this operation. 5) There is no formal code-sharing ori:nter1ine agreement between any Jegacy carrier or major carrier I:Uld the Operator. We believe that such agreements are critical to tbe success ofthe proposed operation. 6) There appears to be an absence in the Operator's proposal ofdollars colllJllitted to the marketing and promotion ofthis new product (the airline) ond these new services (routes, schedules. pricing, etc.). Mr. Hackett stated that $25,000 was eannar.ked for this. By c::ompadson Cnpe 

### Air's annual commitment to this work: was $40,000. 7) We find theproposed subsidy mnounts to be excessive for whatDOT and the communities would be getting.
While we maybe inclined to support the Operator's proposal ofthe four roundtrips a day to IAD, we also have severa.1 concerns related to this. First, we stress ourinterest in participating 

### in detennining the final flight schedulefor our community. As in the past tho need remains for a very early morning departure fromHGRfor our business traveJers and for a well timed last departure from lAD which would be able to capture those passengers returning from points west. These scheduling requirements suggest that the Operator should "originate" its first morning 

### departure from HGR. 

### Mr. Hackett stated during our meetingthat hepurposeJy proposes off-peak timing for HGR's arrivals and departures at lAD to pJacate some ofthe airlines he has been speaking with about gate utilization. We believe this to be counterproductive and contrary to our objectives to make this service successful and self-sustaining. Additionally, 

### Mr. Hackett's comments about his vision ofthe future ofStmAir struck us as alanning. Stating his understanding ofthe tentative status ofthe EAS Program and inparticular the fragility ofthe eligibilityofHagerstown and Lancaster, Mr. Hackett went on to say he sees an opportunity (for one ofhis other enterprises) to connect our communities to a nearby airport "Hub,by shuttlebus once subsidy is gone. We acknowledge the delicateness ofour situation with the BAS Program but vlcw things very differently. We remain optimistic about HGR's ability to grow as commercial service airport and we see the BAS Program as an important tool to help get us there.
In the absence ofcommitments from BWl orlAD for the space necessary for this operation 

### Mr. Hacketthas suggested that it may be necessary to start the service at BWI, then once gate space has been secured at IAD. to petition DOT to shift the service to lAD. We find this proposition unacceptable,
Jn summary, ofthe two options submitted by Sun Air Express, ILCd/b/a Sun Air for Hagerstown,s EAS contract, only ''Service Option 21t describing daily service to and from Washington Dulles International Airport (lAD) would be acceptable to Hagerstown. However, given the number and significance ofthe details that remain unresolved with this proposal. and the general Jack ofcommitments from airport and airline stakeholders, we question if

### it would not he best to reject this proposal inits entirety and rebid these contracts.MAY-29-2012 10: 00A FROt1:**HAGERSTOWt~-WASHI**NGTO 2403132281

Dennis DeVany May24. 2012 Page 3 of3 T0:912023557538

Please note that the Airport,s ultimate objectiveremains to achieve selfsustainabilityas a commercia] service airport. We appreciate the good work ofyour Office and the opportunityto comment on tho submissions for Hagerstown's BAS contract. Please don't hesitate to contactus ifyou have any otherquestions.

P · li

. Ridenour, C.M. AilJlort Director
CC: Mr. Brian Swanson