### Proposal Under the Alternate Essential Air Service Program

Docket s DOT

- OST

- 2004

- 18715 and DOT

- OST

- 1996

- 1711

Submitted by 

### Manistee Blacker Airport Authority Barry Lind Airport Director 2323 Airport Road Manistee, Michigan 49660



### DUNS# 948868799

EIN 382169455

MI

- 001Manistee Blacker Airport Authority Alternate Essential Air Service Proposal 2



## Manistee Blacker Airport Authority Alternate Essential Air Service Program Grant Proposal

The Manistee County Blacker Airport currently receives subsidized air service through the Alternate Essential Air Service Program. We are the only airport to have ever participated in this program. As our first two

- year grant under the program nears its end,

the Mani stee Blacker Airport Authority respectfully submits this Application for continued participation in the Alternate Essential Air Service (EAS) Program.

Understanding of Proposal R equirements

The submission of this proposal and participat ion in the Alternate EAS Program is contingent upon the ability of the Manistee Blacker Airport Authority to enter into

contractual commitments with third parties under terms satisfactory to the Manistee Blacker Airport Authority. In other words, if this proposal we re approved, but the

conditions of the award were different than what is requested or the Manistee Blacker Airport Authority i s unable to secure the commitment of other parties in accord with the terms proposed h erein, then the request to continue particip ation in the Alternate EAS Program and to forgo participation in the Basic Essential Service Program is withdrawn

. Further, the request to continue participation in the Alternat e EAS Program is based upon our understanding of 49 USC Section 41745(f), that if the pro gram no longer addresses

the needs of the Manistee Coun ty Blacker Airport the airport would be accepted back i nto the Basic Essential Service Program

.

Existing Air Service

By virtue of Order 2012

- 3

- 9, dated March 16, 2012, Manistee/Ludington, Michigan participates in the Alternate Essential Air Service Program. The Alternate EAS air service is provided through scheduled public charter flights provided by the Part 380

indire ct air carrier Public Charters, Inc. and direct air carrier Corporate Flight Management. That service currently consists of 6 weekly flights between Manistee and Chicago Midway Airport on 19 seat BAE Jetstream 32 equipment.Manistee Blacker Airport Authority Alternate Essential Air Service Proposal 3

Service History

Manistee/Ludi ngton, Michigan has been a recip ient of Essential Air Service subsidies since 1997, having had unsubsidized service for nearly the first 20 years after the inception of the program in 1978.

The Manistee County Blacker Airport has a long history of commerc ial air service. Commercial airline service spans more than 50 years; the timetable is as follows:

− 1961: Manistee, Michigan receives its first commercial flight, with service provided by North Central Airlines.

− 1961

- 1979: North Central Airlines provides se rvice with the Convair 340, later the Convair 580. The service primarily operated short routes to Chicago and Detroit via Grand Rapids and other cities to the south with continuing service to various cities to the north. It was during this period that Ma nistee would see its best level of enplanements up until 2012 (8 499 total passengers in 1968).

− 1979

- 1981: Republic Airlines, formed as the result of the merg e r of North Central and Southern, continued to provide commercial service to the

Manistee Blacker A irport during the first years of airline deregulation. However soon after deregulation, Republic stopped service. This began a long period of decreasing quality of service with frequent carrier and schedule changes. Enplanements were severely impacted d uring this period and would never really recover (2628 average total annual passengers during 1980's).

− 1981

- 1982: Simmons Airlines took over commercial air service with 18 seat

EMB 110 aircraft.

− 1982

- 1984: American Central Airlines took over commercial air service also

with EMB 110 aircraft.

− 1984

- 1988: Alliance Airlines took over commercial air service with Cessna

402 aircraft.

− 1988

- 1 996: Alliance Airlines was acquired by Great Lakes Airlines in 1988 beginning the longest period of service by a carrier sinc e North Central. It was during this period that Great Lakes began operating as United Express.

− 1996

- 2002: With a notice to terminate service at Manistee the era of unsubsidized service ends and that of EAS subsidies began. Great Lakes Airlines acquired t he essential air service contract to keep our c ommunity connected to the national air transportation network. In 2001 with the loss of
the United Express code share, Great Lakes reorganizes and moves operations west, ending service in the u pper midwest.

− 2003

- 2008: Skyway Airlines dba Midwest Connect was awarded the essential air service contract. With the change in carrier also came a change in hubManistee Blacker Airport Authority Alternate Essential Air Service Proposal 4

with a switch from Chicago O'Hare to Milwaukee. Service was provided by

19 seat Beech 1900D aircraft. Sho rtly after Skyway began service passenger enplanements began to rise after two decades of stagnation. In 2003 total

pas sengers increased 14%; 2004 +35%; 2005 +0%; 2006 +40% and 2007

+8%.

− 2008: Manistee experien c ed a two month suspension of service when S kyway discontinued operations.

− 2008

- 2011: Great Lakes Airlines returned to Manistee. Service continued to be provided to the Milwaukee hub. For the first time in the nearly fifty years of commercial service, service was provided exclusively via non

- stop flights to a hub. In spite of the many short comings of the Great Lakes service (no code share with a carrier at the Milwaukee hub; no interline or baggage agreements with 3 of the top 4 carriers out of Milwaukee; and generally poor performance, both on

- time as well as flight completion), the passenger numbers soon exceeded the numbers of the previous carrier reaching levels

not seen since the 1970’s.

− 2011: Chautauqua Airlines dba Frontier Airlines begins non

- stop regional jet

service with 37 seat EMB

- 13 5 aircraft to their Milwaukee hub. Passenger numbers increased by over 300% to a total of nearly 22,000 for 2011, three times the previous best years during the 1960s, and nearly ten times the numbers during the 1980's, 1990's and early 2000's.

− 2012: Cha utauqua Airlines dba Frontier Airlines ends service in March after only 11 months due to the discontinuation of its hub operations at Milwaukee

Wisconsin

.

− 2012: Manistee experienced a two

- month suspension of service when Chautauqua Airlines dba Frontier Ai rlines ended service in March due to Frontier’s dehubing of Milwaukee.

− 2012: Manistee County Blacker Airport is the first airport to apply for
subsidized air service under the Alternate Essential Air Servi ce Program and

is awarded a two

- year grant for Alte rnate EAS.

− 2012: On May 24 th scheduled public charter service under the Alternate EAS program is provided by the Part 380 indirect air carrier Public Charters, Inc. (operated by direct air carrier Aerodynamics Inc.). Service begins with 4 times weekly ser vice to Chicago Midway Airport with 50 seat EMB

- 145 aircraft, expanding to 6 times weekly in June and daily service in September.

− 2012: In October Aerodynamics, Inc. abruptly halts service and eventually declares bankruptcy. Manistee experiences a one

- mo nth suspension of service, its s econd suspension during the year.

− 2012: On November 15 th , scheduled public charters resume with CorporateManistee Blacker Airport Authority Alternate Essential Air Service Proposal 5

Flight Management the new direct air carrier with service being provided 4 times weekly with 19 seat BAE Jetstream 32 equipment.

− 2013

- 2014: Scheduled public charters flights continue being operated by Public Charters, Inc. and Corporate Flight Management with 4 times weekly service operated by 19 seat BAE Jetstream 32 and during peak summer season

with 30 seat BAE Jetstr eam 41 aircraft, through the end of the two year Alternate EAS grant agreement. Service increases to 6 times weekly in March 2014 after Corporate Flight Management receives Commuter Authority from

DOT.

Community Air Service Needs

Manistee/Ludington has participated in the standard EAS program since the late 1990's. Manistee/Ludington not only meets the legal criteria for “eligibility”, but also epitomizes the type of community the EAS program was intended to serve. The community is geographically isolat ed from the nation’s air transportation hubs:

• 264 miles / 4 hours 51 min driving time to MDW (large hub)

• 274 miles / 4 hours 23 min driving time to DTW (large hub)

• 282 miles / 5 hours 6 min driving time to ORD (large hub)

Manistee suffers isolation from al l of the nation’s passenger transportation networks. The nearest Interstate Highway is 86 miles or 1 hour and 27 minutes away. Manistee is without passenger rail or regional bus service. The two

- lane highway travel available to the community is slow and time consuming. Consequently, reliable air service to the community is essential to the re gion's continued economic development

. According to a Boyd Group study commissioned by the Michigan Department of Transportation

- Aeronautics Division, the Manistee County Blacker Airport has historically been experiencing 85% to 90% passenger leakage to other airports. By providing quality service at reasonable prices, we can improve significantly on the

historic 10%

- 15% catchment as was demonstrated during Frontie r’s brief time of service

to Manistee.

If air service were to be discontinued, the direct and indirect impact on this region’s economy would be far reaching. Local businesses would be forced to use other airports considerably further away for their airline travel options. The local tourism industry would be equally affected by removing from tourists an important travel option into this region. Fewer businesses would choose to locate in the Manistee area in preference to

other areas with commercial air serv ice.Manistee Blacker Airport Authority Alternate Essential Air Service Proposal 6

Intent of Alternate EAS Pilot Program

T he Alternative EAS Pilot Program was established in order to allow subsidy eligible EAS communities to deviate from the traditional program in order to provide transportation services that were more beneficial to the individual community than those available under the traditional program.

The Departments Notice announcing the establishment of the program addressed the purpose of the program as follows:

Congress established this Pilot Program to provide communi ties with an
alternative to the traditional EAS

- type service. Typically, the EAS program pays subsidy to regional air carriers to provide two or three round trips a day to a major hub airport with 19

- seat aircraft. The new Pilot program is designed to allo w communities to forego their EAS for a prescribed amount of time in exchange for receiving a grant to spend in	a	variety	of	ways	that	might	better	suit	their

individual	needs. These options are spelled out in statute and include more frequent service with smaller aircraft, on

- demand air taxi service, scheduled or

on

- demand surface transportation, regionalized air service, or purchasing an

aircraft.

We are implementing the Pilot Program by inviting communities to submit applications to use EAS funds in an a lternative manner to address their transportation needs. We	will	use	an	open	and	flexible	format	for	applications because	we	recognize	that	each	community’s	circumstances	may	be	different, and	they	need	latitude	in	identifying	their	own	objectives	and	deve loping strategies	for	accomplishing	them. At the same time, general, vague, or unsupported applications will not be entertained. The more highly defined the application, the more likely it will receive favorable consideration. (Emphases added)

The overall goal of the Program is described in the Notice as follows:

“ We seek proposals that are fully thought out and are designed to meet the individual needs of a community

. We	encourage	proposals	that	have	the greatest	chance	of	increasing	passenger	usage	and	t herefore	reducing	the need	for	future	subsidy	under	either	the	EAS	or	Pilot	Program.”

Summary of the Alternate Essential Air Service Proposal

The Manistee Blacker Airport Authority desires to continue receiving air service in the

same manner as it has for the previous two years under the Alternate EAS program. That is air transportation conducted by a Part 380 Indirect Air Carrier contracting with an FAA

app roved Part 135 and/or Part 121 direct air c arrier. Such air transportation would be to a

medium or large hub with twin

- engine aircraft conducting regularly scheduled public charter flights. The frequency of flights will vary seasonally as required to meet demand.Manistee Blacker Airport Authority Alternate Essential Air Service Proposal 7

Why Continue with Alternate Essential Air Service for Manistee?

There are two factor s we believe are critical for successful air service at small rural communities like Manistee/Ludington. Those two being 1) quality reliable air service at a 2) reasonable price. Historically we have had neither at Manistee under the standard EAS program . With the exception of the 11 months of service provide by Frontier, reliability was always an issue with far too many flight cancellations and delays and fares were also high as compared to more distant airports . The combination of poor quality,

unreli able service along with high average fares encouraged people to drive significant

distances for more reliable and cost effective air service.

That has changed with our service the past two years under the Alternate EAS program. During calendar year 2013 99 % of all scheduled flights completed and 89% completed on time, including two months (March and September) where every flight (100%) completed

on time. Even during this past harsh w inter (where we have received a rec ord amount of

snow fall with over 200" ) 95% of flights completed and 85% completed on time (Dec '13

- Feb '14).

Another measure of quality is the response from our passengers. As part of our overall marketing efforts we survey every passenger who flies out of Manistee in order to better

unders tand their experience and needs for air service. In response to t he following question: “How likely is it that you will recommend the Manistee Airport to othe r s?” of those passengers who flew during 2013 and responded to the surveys, 91% responded “Very Likely”, 7% responded “Somewhat Likely” and only 2% responded “Not Likely.” The response to this question along with the responses to other survey questions indicate that the overwhelming majority of our passengers think highly of the quality of the

servi ce we are providing at the Manistee airport.

Overall fares have remained reasonable as well. The average fare between Manistee and Chicago Midway was $86.74 each way in 2013. Standard pricing for round trip fares ranges from $120 to $240. By maxing out the fare at $240 RT, even a last minute purchase on a full flight is still available at a reasonable fare.

In addition to the quality of the service and reasonableness of the airfares, there are many

other factors that lead us to want to continue with Alt ernate EAS. Among these other

factors is the productive working relationship we have with Public Charters, which includes weekly meetings to discuss marke ting strategy and efforts, good communication on all customer service issues, coordination on schedul ing, pricing and customer service policies.

While participation in the Alternate EAS Program is orders of magnitude more work than standard EAS for the airport (and we warn all other airports who a sk us about the

A lternate EAS program of this fact), we bel ieve that it ultimately works better for us than standard EAS because the air carrier and the airport are working together as a team in order to be successful. That hasn’t been our experience with standard EAS. The natureManistee Blacker Airport Authority Alternate Essential Air Service Proposal 8

of A lternate EAS forces the air carrier and airport to work together which we believe is

critical to success.

Even though the past two years under Alternate EAS has not been all rosy (with Aerodynamic s ’ bankruptcy, Corporate Flight Management’s delays in obtaining commuter authority), we feel that we need to continue with what we have started in order

to build on the effort that we have invested. To return to standard EAS at this time would be premature . Only now after nearly two years of Alternate EAS service are we finally getting past the growing pains, and we feel it would be premature to end our experiment at this point in time. In fact we feel so confident in the long term benefits of what we

hav e undertaken that we desire to not only continue with Alternate EAS, but to do so for an extended period of four (4) years instead of the more standard two (2) years.

Why Do We Reject the Standard EAS Proposal of Sun Air?

In addition to all the reasons a bove why we believe that Alternate EAS is working for us and which we believe are reason enough for us to continue with the Alternate EAS program, there are also significant concerns we have with the one standard EAS proposal received by DOT in response to Order 2014

- 2

- 1 requesting proposals for standard EAS at Manistee. This proposal was submitted by Sun Air. The proposal contained two options. Opt ion 1 entailed service to both Chicago Midway Airport and Milwaukee Airport with 17 weekly fl i ghts off seas o n (7 weekly to Milwaukee and 10 weekly to Chicago Midway) and 33 weekly flights during peak season (11 weekly to Milwaukee and 22 weekly to Chicago Midway) for a subsidy of nearly $3.2 million. Option 2 entailed service to only Milwaukee with 18 weekly f l i ghts off season and 24 weekly flights during peak season for a subsidy of nearly $2.6 million. All flights would be operat ed with twin engine Piper
Chieftain aircraft with room for eight (8) passengers per flight.

The first concern we have with the Sun Air proposals is the viability of Milwaukee as a
destination for our service. While we have had service to Milwaukee for the vast majority of the last decade, the situation at Milwaukee has significantly changed in the last two years, to the point that we no longer see it as a viable hub. During the entire period when we utilized Milwaukee, there was an air carrier ope rating there operating a true hub operation based in Milwaukee (Midwest Airlines and then Fro n tier) . However since Frontier’s dehubing of Milwaukee there is no longer an air carrier conducting hub operations at Milwaukee. As a result the number of non

- stop destinations served from Milwaukee is roughly half what it used to be and less than half of other regional airports

which still have hub carriers based at them (ORD, DTW, MDW). While Milwaukee meets the technical definition of a medium hub airport, it does not have the connectivity to the national transportation system that a true “hub” airport has. While we realize that
there is some O/ D travel between northwest Michigan and southeast Wisconsin that does desire air service between the two regions, our survey information indicates that there is significantly more O/D demand between Chicago and northwest Michigan than southeastManistee Blacker Airport Authority Alternate Essential Air Service Proposal 9

Wisconsin a nd northwest Michigan. Th erefore we eliminate Sun Air’s O ption 2 from

consideration.

That leaves O ption 1 for considera tion. The first concern about O ption 1 is the total subsidy requirement. At almost $3.2 million that is about 50% greater than our cur rent Alternate EAS grant. The second concern is with the proposed flight schedule. The proposed schedule has the aircraft based in Milwaukee. The effect of this is that the first flight of the day is Milwaukee to Manistee (and the last flight of the day is Manistee to Milwaukee). These flights are only conducive to O/D t r avel as they do not work for connecting to other flights in Milwaukee (morning flight leaves before most other connections would arrive in Milwaukee and the evening flight arrives in Mi lwaukee after most connecting opportunities). We feel that only by overnighting the aircraft in the spoke airport (Manistee in this case) can you most effectively service the non O/D passenger that intends to connect to other destinations. While this sch edule does provide service to a true “hub” airport in Chicago Midway (Southwest Airlines largest hub) that amount of service is less than the demand that we have averaged during the current Alternate EAS period. For example during the most recent period w e have averaged 9.0 passengers per flight October 2013 through March 2014 , with only 8 seats available on most days to Chicago we would need to have virtually 100% load factor to continue to service the demand we have built up through our marketing efforts around our current Chicago Midway service. So for these reasons we eliminate O ption 1 as well.

Finally there are two other factors that come into play when reviewing the proposal from Sun Air. One being the poor reputation Sun Air has earned dur ing thei r other EAS

eff orts. After talking to the managers at some of the airports they curr e ntly provide service to, the general feedback was not favorable. I realize that they claim in their proposal to have recently addressed their service issues with new man agement, but it is too early to tell if that is truly the case at this point. The last factor against Sun Air is the

aircraft the y operate. While a Piper Chieftain is a safe aircraft, it is not what our passengers tell us they want to fly on. Given that during significant parts of the last three years we have had service with regional jets, an eight passenger piston aircraft is not what

our passengers have come to expect. We feel t h at a 19 seat turboprop is the minimum level of equipment that will be ac cepted by the local market. Anything less and it will be difficult to attract enough passengers to be successful. For these reasons we reject the Sun Air proposal.

When we use the word “reject” here in relation to Sun Air’s proposal, we realize that the proposal technically meets the requirements for EAS (at least two daily flights to a medium or large hub airport with two pilots and twin engines) and is a valid standard EAS proposal. However we reject it in the sense that we find the proposal inferior t o our preferred Alternate EAS service proposal presented here for the above reasons.Manistee Blacker Airport Authority Alternate Essential Air Service Proposal 10

Discussion of Important Aspects of the Alternate Essential Air Service Proposal

One of the original reasons we desired to be the first to participate in the Alternate EA S Program was to be able to utilize the flexibility inherent in the program to craft service that not only meets our needs best but also does so at what is hopefully less subsidy than otherwise would be required for standard EAS. We kne w that our market i s highly seasonal and what is appropriate in July is not appropriate in January as it relates to both frequency and total n umber of seats operated. T he flexi bility Alternate EAS provided us the ability to adjust frequency to the actual demand.

Table 1 . The seasonality of passenger loads at Manistee from 2001

- 2010. This table shows the monthly passenger loads averaged over the decade. With 100 representing the average number of monthly

passengers.

As the data in Table 1 shows, the historical passenge r demand in Manistee is seasonal with July and August being the peak months and January and February being the low

months. The difference between the winter and summer months is about 2.5 times.

We have utilized the flexibility of Alternate EAS to adjus t our schedule the last two summers to reflect this seasonality of demand. This coming summer we are going a step further and adjusting the schedule by day of week as well. In fact the currently published schedule for this coming summer (July and August) has flights varying by aircraft type during the week (mix of 19 seat and 30 seat aircraft) and frequency (some days have one frequency others two). This allows us to tailor capacity to the historical demand we have experienced the past two summers. For example a typical week of the summer schedule

looks like this:

Monday: 38 seats inbound, 49 seats outbound

Tuesday: 19 seats inbound, 19 seats outbound 0 20 40 60 80 100 120 140 160 180

Feb Apr Jun Aug Oct Dec %	of	Average	Monthly	Passengers

AverageManistee Blacker Airport Authority Alternate Essential Air Service Proposal 11

Wednesday: 19 seats inbound, 19 seats outbound

Thursday: 38 seats inbound, 38 seats outbound

Friday: 49 seats inbound, 38 seats outbound

Saturday: 30 seats outbound, 19 seats inbound

Sunday: 49 seats inbound, 38 seats outbound

We believe that with the ability to tailor the schedule to the historical and anticipated

demand we can operate more efficiently with higher load factors . This should over time

reduce overall subsidy costs.

In the continued spirit of the flexibility that the Alternate EAS program provides, in this current proposal we are requesting the following additional areas of flexibility:

1) Hub Airport

– While we are satisfied with Chicago Midway as our hub airport, we would like the opportunity to experiment with other large or medium hubs in the area. It may turn out that through such experimentation we discover something that works better

tha n Chicago Midway or works in addition to Chicago Midway.

2) Non

- stop vs. one

- stop, downline and upline service

– Traditionally we have had one or more stop service for the vast majority of the time we have had commercial air service, and only within the la st few years have we had non

- stop service. While we have seen

that non

- stop service seems to be vastly preferred to one

- stop service, we may want to experiment with some one

- stop service as well. Why would we consider this? Ultimately in order to reduce required subsidy amounts over time we need to increase revenue and lower costs. We can increase revenue by ensuring that w e fly full(er) aircraft. We need to be reaching industry standard load factors of 75% or more in order

to be successful in this mea sure. On the cost side of the equation, in the long term in order to reduce costs per passenger we need to be operating larger aircraft with high load factors. The cost per passenger for an 80% full 90 seat aircraft is less than an 80% full 50

seat aircr aft is less than an 80% full 19 seat aircraft, e tc. To ultimately reduce subsidies we need to be operating high load factors on larger aircr a ft. To do that we need to be looking at ways to pool passengers from more than one airport. In the foreseeable f uture there will not be enough demand to fill aircraft larger than 50 seat s solely from Manistee enplanements. We desire the flexibility to test combinations with other cities both downline and upline to see if we can identify something that works.

Level of Subsidy Requested

We have taken into account many factors in producing this proposal. We desire to have a reasonable level of service in order to satisfy the needs for air transportation in our communities. We also realize that we need to be good s tewards of taxpayer funds. A lso in requesting a four year grant we need to be confident that the amount is not only sufficient this year but also four years from now. To t hat end we are requestingManistee Blacker Airport Authority Alternate Essential Air Service Proposal 12

$2,328,103.54 per year to provide air service under the A lternate EAS program for a period of four (4) years . That amount of would subsidize up to 15,372 available seats between Manistee and Chicago Midway Airport or 2,889,936 available seat miles (ASM). We are requesting reimbursement under the Alternate EAS grant at a rate of $0.80559 per ASM flown. This reimbursement formula allows flexibility to operate different sized aircraft as well as the option to try service to different hubs than Chicago Midway if determined in the best interest of the community and airport during the term of this proposed four year agreement. We realize that this subsidy level is higher than that requested for the current agreement, but feel that the level of subsidy is consistent with other standard EAS agreements and is less than the bid provided by Sun Air for service to Manistee. In fact in comparing the level of subsidy requested under the Sun Air bid using an apples to apples comparison method we find the subsidy level for Sun Air Option 1 is about $0.85929 per ASM as specified in their proposal ($3,184,192 / 3,705,601 ASM = $0.85929/ASM) and for their Option 2 the rate is $0.95066 ($2,595,134 / 2,729,825 ASM = $0. 95066/ASM). So not only is our total subsidy request less than Sun Air’s proposal

in terms of total dollar amount, it is also less on an ASM basis as well (which takes into

account differences in the number of seats flow n and the distances involved as these factors vary between Sun Air’s two options and our A lternate EAS proposal). In addition
I believe the S un Air proposals are incorrect in the stated number of ASMs in each proposal. I believe based on the number of departures documented and the flight distances between airports that they used 9 available seats on each aircraft for their ASM

calculation inst ead of 8. Their proposal calls for only 8 passenger s eats with two crew, so the correct number to use would be 8 available seats for their ASM calculation. Using

this number we determine that the true costs of the Sun Air Option 1 is $0.96841 per ASM ($3 ,184,192 / 3,288,064 ASM = $0.96841/ASM) and Option 2 is $1.07604 per ASM ($2,595,134 / 2,411,756 ASM = $1.07604/ASM) both significantly higher than our proposal

. Unlike the proposal two years ago when very much was unknown (eg. costs at Midway were signi ficantly underestimated) as we embarked on the unknown path of Alternate EAS, we are confident that our current proposal is reasonable and accurately reflects the costs to provide the service specified and we also believe that this rate ( baring unforeseen

circumstances like a significant spike in fuel prices for an extended period of time) is reasonable for a period of four years.

Detailed Alternate Essential Air Service Proposal

The details of the proposal are specified in a separate document that focuses on just the proposal request. This companion document is intended to provide context to the specifics in the detailed proposal.