09/27/2012 16:09 7872763846 

### L A IRIZARRY ASSOCIA

AVJATION

CONSULT ANT 

# L.A. IRIZARRY & 

# ASSOCIATES

September 27, 2012 P.O. BOX 37217 LUIS Ml;floz MARIN INTERNA'TIONAL AIRPORT SAN JUAN, PUERTO RICO 00937-0217



### Aloha Ley Office of Aviation Analysis 1200 New Jersey Ave. SE. W86·310 Washington, DC 20590 TELS. 

## mm 75?·7621 • FAX 1787) 276·3846 

### E-mail: irizarry@icenetworks.com

RE: SmaH Community Air Service Development Program Docket**DOT-OST-2012~006** 

### Consortium of the PRTC and RlAC Dear Aloha: PAGE 01/08



# znz

Why I am not surprise of this new that the Government of Puerto Rico don't want to call it a new

· APP (Public-Private Partnership Association) to privatize this aviation service between San Juan

International Airport and Culebra Airport. The same as they are doing with the Luis Munoz. Marin International Airport., given it to a foreign operator from Mexico.
I am and all my clients are in opposition to this, which list will follows:
Air Charter, Inc. Island Air Charter Inc. Ace Flight Center Aerotim Cargo International, Inc. Bevin Air Service Charter Flights Caribbean 

### VI Air Link Clair Aero, Inc. Servicios Aereos Profesionales, 

### S.A. Servicios Aereos Profesionates, Inc. Aerolfneas Santo Domingo, S.A. Air Sunshine, Inc 

### Jet Center, 

### Inc
I will like to brlng to your attention the following based on the published information and requirements for the Small Community Air Service Development Program funding to Cape Air for the "Culebra Service'.

### 09/27/2012 15:09 7872753845 

### L A IRIZARRY ASSOCIA PAGE 02/08



### A. Eligible 

### Appl;cants

Eligible 

### applicants are smallcommunmes thatmeetthe following 

## .statutory criteria ( 49 

### U.S. C. 417 43): 1. As 

### of calendar

### year 1997, the airportseJVing

### the community 

### was notlargerthan a 

### .smallhub airport. andithas insufflcientaircarrierservice orunreasonablyhigh air

### fares; and 

### Since 1997 and long before that, Culebra has been serviced with a reliable, sate, reasonable and senous air service_ It does have and today have sufficient air carrier service with reasonable fares. 2. The airportserving the communitypresents characteristics, such 

### as geographic diversity 

### or unique circumstances thatdemonstrate the needfor, andfeasibility

### of. grant

### assistance 

### ftom the Smaffcommunity 

### Program. There is no diversity or unique characteristic for this airport. Communities without existing 

### airservice: Communities that

### do notcurrentlyhave commercialairservice 

### are eligible 

### forSCASDP 

### funds, 

### butairservice providers musthave metor

### be able to

## meet in a 

### reasonable periodall Departmental requirements forairservice certification, including safetyandeconomic authorities. 

### This is not the case of Culebra Airport Not only 

### it have sufficient air carrier services by 

### three airlines and several charter services, the community also have marine services between Fajardo and Culebra Island.
Ellgible Projects 

### The Depattment is authorized

### to awardgrants under49 

## u.s.

# c. 417 43

### to communities that

### seek

## to provide assistance 

### to: An aircarrier

## to subsidize service to 

### andfrom an underservedairportfora periodnot

## to exceed3 years; 

### Why**~he** 

### Department does 

### not provide those funds to 

### help the actual 

### air carrier 

### servicing Culebra to 

### expand its services instead of 

### giving this money to bring 

### a carrier that never provided services 

### to Culebra and will come and put these 

### air carriers 

### out of business with the help of the Government of Puerto Rico and the funding of 

### the Department, which are moneys from the public. An undersetvedairport

### to obtain service 

### to and ti'om 

### the undernervedairport; 

### and/or An under.served airport to 

### Implement such otherllllU)Sures 

### ss the 

### Secretary, in consultation with 

### such 

### airport, considers appropriate 

## to improve airservice both 

### in terms 

### ofthe 

### cost of such service 

### to consumers andthe availabil;tyofsuch service, 

### including improving airservice through 

### marketing andpromoffon of 

### air service 

### and enhanced tmlization ofairportfacrTdies. 

### This is not the case also, Culebra Airport is properly served with regular air carrier service and also Charter service, and with the consultation with whom, the Mayor of the City was never consulted of this proposal. like everything that this actual Government has been doing, in the dark, and behind doors, they make deals and not considering the people of Puerto Rico and in this case Culebra, which is the ones who pays their salary. The Tourist Department of Puerto Rico never had market not make any assistance to the local air caniers to promote, increase and improve the service provided.

### 89/27/2812 16:89 7872763846 

### L A IRIZARRY ASSOCIA PAGE 83/08



### Nowthey are expending tha money ofthe Puerto Rico Peopla in another air carrier, which already have the Essential Air Service for Mayaguez Airport, had the Ponce Airport when in fact was the one that with the highest bidding for this service. We have to ask yourself, was the Essential Air Service biding fair and equal to others, when they was granted the bid when they were the highest bidder? Was not this a political issue due to the owner 

### of Cap Air? ls the Government and possible 

### the Department financing Cape Air in 

### its ·operations? The credibility 

### of these types of 

### program is in question. Applicants also shouldkeep in mindthe following statutory restrictions on eUgible projects:
An applicantmaynotreceive 

### an addiUonalgrant

## to support the same projectfrom 

### a previous grant (see Same Project Umitation, below); and 

### cape Air, which the air carrier granted with these funds have additional grant, as previously indicated, Essential Air Service. This is not mentioned in the proposal.
An appficantmaynot receive an addifional grant, prior

### to the completion of its prevk>us grant (see Concurrent 

### GrantLimitation, below). 

### Again, Cape Air, 

### which the air carrier granted with these funds have additional grant, as previously indicated, Essential Air Service. This is not mentioned in the proposaL It is clear that in the proposal, what Cape Airwill do is operate during the high season in each place, 

### ifyou look good at the proposal, Cape Airwill operates in summer in the Block Island Airport and in winter in Culebra_ Where is the need for the services when they only 

### will conduct 

### operations to be benefits of the tourism season? Why they do not conduct operations in winter in Block Island, because no one 

### fly there in winter. Is this a real service to the people of Culebra and Block Island? Of this isjust another way to obtain money from the Government? You should answer it.



### A Priority Selection Criteria The law directs the Department to give prtorttyconsideration 

## to those communities 

### or consortia where the following criteria are met: Airfares are higherthan 

### the nationalaverage airfares forallcommunities-DOTwill compare the local community's air fares to the netionalaverage airfares for allcommunifies. Communities 

### with airfares significantlyhigherthan the nationalaverage airfares forallcommunities will be given priority_ DOT calculates these fares using the Bureau ofTransportation statistics (BTS) database_ BTS Origin Destination Survey dais is used

## to gather fare data for

### all markets thstserve airports represented In SCASDP applications. 

### The SCASDP air fare comparison report represents 

### a community's (each individual appticanf.s) airfares as a percentage of NationalAverages (Fare Premium). The report compares a community·s air fares 

## to the average for all othermarkets in 

### the Country that have similar density (passenger volume) anddistance characteristics {marketgroupings). The Fare Premium calculation includes allmarkets thataveragedmore than 1 passengera day. 

### The 

### air fares are not higher 

### than the 

### national average airfares for all communities in Puerto 

### Rico. There is no need to give priority to this community as the air fare are very reasonable and fair and the service provided is enough and all year round.09/27/2012 15:09 7872753845 

### L A IRIZARRY ASSOCIA PAGE 04/08



### As a matter 

### of fact, at this moment the Government of Puerto Rico is in the process of transfening the Luis Munoz Marin 1ntemational Airport to a foreign private company under a 

### 40 year lease agreement. 

### This 

### will not only increase the fare for the flights to be conducted between this aircraft by Cape Air and Cu!ebra but 

### will remain for the next 40 years as long as the airport is privatized. Is this the purpose of these programs? Is this 

### the purpose of granting the money to Cape Air and in another hand, eliminating the setvice provided to Culebra from other airports like Isla Grande Airport, which is located 5 miles from the Luis Munoz Marin International Airport? 

### Our opinion is 

### that the Government 

### of Puerto Rico, through the Tourist Department 

### and Ports Authority want to eliminate the local operators and put thousands offather's and mothers of families out of

### a job as they already did to over 30 thousands ofthem and using the Department to do so_ 

### 2_ Participation-DOTwill consider whetheran application has broadcommunityparticipation, including:

Whetherthe proposedproj'ecthas broadcommunitysupport; and The 

### community's demonstrated commitment

## to andparticipation in the 

### proposedproject. 

### If 

### in fact 

### the Department considered that the application broad community participation, I recommend that you looks at the docl<et, there are more letters in oppositions to the project than in favor. Up to 

### the point that 

### the Mayor ofthe Culebra Community was never consulted about this, as previously indicated this was done behind closed doors and at the black of the night. No community participation was demonstrated nor did any participation have the community. Hope you consider the about and may take whatever actJon is appropriate_
Sincerely,

Robert 

### A. Letteney Deputy Assistant Secretary for Aviation and International Affairs_09/27/2012 15:09 7872753845**~'rancisco** 

### Toms**-l~iccrion** 

### to Cape:: Air) 

### L A IRIZARRY ASSOCIA PAGE 05/08 l'age 1

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# ,......

Document Details

·.................... .. 

### Francisco Torres- (Objection to Cape Air)**Vl~** Document:**~· t;''~** 



### Comment:

To Whom It May Concern This is to ln'l'orm of**o~tr** totl3l objection to the application !Submitted by Cape Air to take part in the "Smell Community Air Service Development Program" for the Island of Culebra, Puerto Rico. Air Flamenco is a commuter air carrier that has been providing air passenger and cargo servlceG \'0 Culebra Island for many year'S; very similarto the servic®s New England**Airline::~** provide 1:0 Bloc!< Island, Our Company has been there giving service 24f7, 24 hoLir medical transportation to Island residents and visitors alike. We ere native of Culebra Island and have been operating since September, 1976. We were not aware of this application or DOT Program until July 18, 2012; one month past the application due date of June. We were informed by New England Airline, which we understand was informed short before the closing date, To say that Air Flamenco does not provide adequate service to**O\~r** major airport is nal: true. because we have a counter station in San Juan lntematlonl'll Airport to serve and connect with all major airlines. To say that Culebra Island is isolated from thlil rest of the world is false. Air Flamenco and New England Airlines, already have end operate the proper aircraft needed to sef"l/e our Islands; combined a total of ·RHeen (15) aircraft, support equipment and spare!;; to keep our fleE!t**~fely** flying for many**yea~** to come. We belive that granting or subsidizing another carrier where other Companies**a~** afrgady offering this service for many years is not only untslr but discriminating, Local companies were not advised on time of the availability of the Small Community Air Service Development Program. At t.hls t.ime, Cape Air do not have the proper equipment to fly to**the~e** Islands, and this would jList put a burden and dilute our thin margin of operational revenue. Franciaco Torres**Pre~ident** Air Flamenco**~** 

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### SU7.annc Hebert 

### (Puerto Rico) 7872753845 

### L A IRIZARRY ASSOCIA PAGE 05/08**Pasr-~** l

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# ,.- Document Details
Suzanne Hebert**(Pn..~~erto** 

### Rico)

Document 10:**DOT-OST-2012.()069-0~02** Document Type: Otne,r Docl<et 10: DOT- OST-:w-12-0069 VIew Document:**~ liC'~·** 



### Comment: Help

...

· .. :**~**..**·.~**

### ...::

.....·. '\-**-.~·:.**

To whom it may**conce~rn:** I am e resident of the Island of Culebre P.R. I heard about this situation the day before last and am extremely concerned for 

### two reasons 1)The agency did not consider our existing small commuter airline Like Air Flamenco. 2)1n an Island so smell bringing in another carrier would be completely irresponsible and hurtful to this Island. The current GovernmMt of Puerto Rico does not represent the majority of what residents want or need. Which is the preservation of it's natural resources and sustainable development. They want to crack this Island open and profit from it. Ruining t.he quality of life we now enjoy. If this Agency truly wants to help wouldn't It make more sense to help our local carrier Air Flamenco pay th@ expensive fees of operlirting from LU/$ Munoz Marin Airport?So they can offer a better 

### service 

### to Tourist's? I cen not help wonder, who does this agency
...truly want to Help?? 

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# ~09/27/2012 15:09 7872753845 

### M. l Stark (Culebra, Puerto RiC<!) 

### L A IRIZARRY ASSOCIA PAGE 07/08**Pns~** 1

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Document Details

M. 

## J. Stark**(Cu~ebra,** 

### Puerto Rico)**Vl~w** Document:**~·** l('i



### Comment:**~** To whom It may concern: While I have friends on 61ock Island, I cen only speak concerning Culebra, Puerlx> Rico. The Puerto Rican Tourism Department is not the same entity ilS one might find on the mainland, as it is totally a**l'ri~r,;~te** organl:tatinn with pol!tlcel tle:s. The ties in thlo; case are to the currant Governor, who Is hugely pro big business and big development, hand in hand with some of the largest investors In Puerto r<ico. Culebra, while a part of Puerto Rico, is 2 very separate place, It is known and loved for its small t.own feel and lack of large development tourism projects. It only has a small footprint as to the number of tourists i1: can support and not be a domiment to the locals, i.e. water. roads. etc. The Cllrrent airlines serve our community well, as well as being locally owned and involved as 

### t'O the community. While the slight lnconvenjence traveling to Isla Grande rather than leaving directly from SJU might be eased, the benefit is not worth the prlca. Culebra is being asked to foot the bill ae if you are doing us a favor. when the Javor is only**~o** ben€fittile airline and its investors, detracting from our local economy, both financially and physically. If this Is wanted by the local Culebrense, let them have a say in their fate, rather then letting the PR Tollrism Depenment and Governor Fortune decide for us. Smell, sustaineble tourism growth. yes. What is being proposed and its potential damage to our Island? No. Thank you for your con$id0ration. Assumed financial rewerds that could forever change our island for the worse is not a worthy goli!l, whereas the simple beauty and passion found on Clilebra should be left to be discovered anew by tourisl'3 forever. And that Is priceless. Regards, MJ Stark Smell business owner/Culebra



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Erica Russo**~** 

### (Objection of Cape Air)

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I am strongly against an airline from out of state (Cape Air of Mess) getting the business contr:act from RIAC to**opera~** betwean two airports in Rl. specifically 

### I F Green and Block Island.**0~1r** state already has an airline that flies in and out of Block Island. :servicing the many residents and visitors on a daily basis. Why would Rl pay another state's business

### to conduct business in our own state. where we already have an airline set up and riJnning be01utifully? Where Is the logic? Alii can say le this concept Is most. disappointing in more ways than one and seems to be profiting !llomeone else, other 1:han our own statQ or island businesses. Whet gives? Rethink this, pleese.

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