**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 M yers 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 , bas ed on assertions and data provided b y Peninsula Airway s (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, 201 0, 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 setti ng procedures for the bush mail rates, all service operated in mainline markets is removed from the bush rate calculations. Similarly , all seaplaneservice operated in markets where wheel plane service is possible is removed from the

calculation of the se aplane mail rate. While the unit costs are assumed to be the same for all operations b y a particular aircraft, removing data for operations operated out of mail rate class reduces the weighting of the aircraft. The Consolidated Carriers documented the co nfiguration of aircraft and onboard passenger seats for these aircraft in its previous filing s .
In this case, all scheduled service published b y Peninsula Airway s in these markets is advertised and operated with aircraft with 10 or more passenger seats fo r the Metroliner and SAAB aircraft. Penair also has in effect a general equalization notice matching the lowest eligible rate in each of the markets lis ted. It was not until August 25 that the Consolidated Carriers were able to confirm, through examinati on 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 specificall y 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 co nsistent 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 thecalculation 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 dire ction of the Rural Service Improvement Act and all policy decisions in this docket.

Cost data for the Metroliner aircraft should be excluded entirel y from the Part 135 rate because Penair asserts that it no longer operates these aircraft ty pe in Part 13 5, are those costs are irrelevant to the transportation of mail in Alaska.

**WHEREFORE:** the Consolidated Carriers move to exclude all data for Peninsula Airway s 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 Airway s 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 equal ized, and for a different class. This motion should be accepted because it is based on information and assertions made b y Penair only recentl y, which could not be confirmed independentl y until today

. Respectfully

submitted, The Consolidated Carriers By Hank M ye rs August 26, 2011**CERTIFICATE OF SERVICE**

I hereb y 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 M yers Augus t 26, 2011