UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

__________________________________________

)

In the matter of the )

)

INTRA-ALASKA BUSH MAIL RATES ) Docket OST-2003-14694

)

__________________________________________)

MOTION OF THE CONSOLIDATED CARRIERS 

TO EXCLUDE DATA OF PENINSULA AIRWAYS

Communications with respect to this document should be addressed to:

Hank Myers

MTC

P.O. Box 7142

Bellevue, WA 98008-1142

(425) 830-4265 (office)

hank@mtcworld.com

August 26, 2011
UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

__________________________________________

)

In the matter of the )

)

INTRA-ALASKA BUSH MAIL RATES ) Docket OST-2003-14694

)

__________________________________________)

MOTION OF THE CONSOLIDATED CARRIERS 

TO EXCLUDE DATA OF PENINSULA AIRWAYS

The Consolidated Carriers, based on assertions and data provided by Peninsula Airways 

(Penair) to the DOT in this docket and as T-100 segment data, moves to exclude all cost 

and segment data for the Metroliner 23 aircraft operated under Far 135 for the 12 months 

ended September 30, 2010, as well as all of the data for the SAAB 340 aircraft operated 

under FAR 135 for mail service to or from the following points:

Mail Point Code Prevailing Mail Rate

Aniak (ANI) Mainline

Atka (AKB) Part 121 Bush

Cold Bay (CDB) Part 121 Bush

Dillingham (DLG) Mainline

Dutch Harbor (DUT) Part 121 Bush

King Salmon (AKN) Mainline

McGrath (MCG) Mainline

St. George (STG) Part 121 Bush

St. Paul (SNP) Part 121 Bush

Sand Point (SDP) Part 121 Bush

Unalakleet (UNK) Mainline

Under mail rate setting procedures for the bush mail rates, all service operated in 

mainline markets is removed from the bush rate calculations. Similarly, all seaplane 
service operated in markets where wheel plane service is possible is removed from the 

calculation of the seaplane mail rate. While the unit costs are assumed to be the same for 

all operations by a particular aircraft, removing data for operations operated out of mail 

rate class reduces the weighting of the aircraft. The Consolidated Carriers documented 

the configuration of aircraft and onboard passenger seats for these aircraft in its previous 

filings.

In this case, all scheduled service published by Peninsula Airways in these markets is 

advertised and operated with aircraft with 10 or more passenger seats for the Metroliner 

and SAAB aircraft. Penair also has in effect a general equalization notice matching the 

lowest eligible rate in each of the markets listed. It was not until August 25 that the 

Consolidated Carriers were able to confirm, through examination of actual mail pay

records, that the prevailing rate in each of the markets is as listed above. In fact, in none 

of the markets where Penair operates service with Metroliner and SAAB aircraft is the 

Part 135 bush rate in order.

Penair has specifically filed data so that its large aircraft that are operated under Part 135 

are excluded from the ratemaking base for Part 121 aircraft. These data should be 

likewise excluded from the calculation of the Part 135 bush mail rate. This exclusion is 

not only consistent with existing practice for Mainline and Seaplane rates, but is 

consistent with the treatment of Part 121 bush aircraft operating in mainline markets. 

The operations of costs of these aircraft are excluded not only from the Part 121 mail 

rate, but also the Mainline rate. Therefore, excluding these operations entirely from the 
calculation of intra-Alaskan mail rates is consistent with all precedent and methodology

in this docket. Including these data in any mail class would be contrary to the direction 

of the Rural Service Improvement Act and all policy decisions in this docket.

Cost data for the Metroliner aircraft should be excluded entirely from the Part 135 rate 

because Penair asserts that it no longer operates these aircraft type in Part 135, are those

costs are irrelevant to the transportation of mail in Alaska.

WHEREFORE: the Consolidated Carriers move to exclude all data for Peninsula 

Airways Part 135 Metroliners from the calculation of the Part 135 mail rate because all 

Metroliner service was terminated before the proposed effective date of the rate. 

Furthermore, the Carriers request that all cost and operations data for Peninsula Airways 

SAAB 340 aircraft operated under Part 135 for transportation of mail to or from Aniak, 

Atka, Cold Bay, Dillingham, Dutch Harbor, King Salmon, McGrath, St. George, St. Paul, 

Sand Point and Unalakleet, Alaska be excluded because those markets are served under 

Part 121 bush service or mainline service, and the prevailing mail rates, to which Penair 

has equalized, and for a different class. This motion should be accepted because it is 

based on information and assertions made by Penair only recently, which could not be 

confirmed independently until today.

Respectfully submitted,

The Consolidated Carriers

By Hank Myers

August 26, 2011
CERTIFICATE OF SERVICE

I hereby certify that I have this day served a copy of the foregoing Motion of the 

Consolidated Carriers upon all parties to this docket by electronic mail.

Respectfully submitted,

Hank Myers

August 26, 2011