### THE 

### STATE 

## of

August 27, 2012

Mr. Dennis J. DeVany Chief, EAS and Domestic Analysis U.S. Department ofTransportation 1200 NewJersey Avenue, SE Washington, DC 20590 Re: Essential Air Service for Diomede, Alaska (DM2) DOCKET DOT-OST-2009-0260 Dear Mr. DeVany, 

## Department

# ofTransportationand PublicFacilities OFFICE OF THE COMMISSIONER
P.O. Box 196900 Anciloroqe, Almko 99519-6900 Moin: 907.269.0730

Fox: 907.269.0489

U1

I am very pleased to provide comments to Essential Air Serviee.(EAS)regarding air service at Diomede, Alaska. Due to the isolated location ofthis island community inthe Bering Straits and the complete lack ofany road connection or scheduled transportation, subsidized air.servicewouldbe the only form ofreliable transportation to the mainland. As youknow Diomede is perhaps one ofthe most remote communities in the United States, butironically is not eligible to use the Basic EssentialAirService program because they did not have scheduledair service when the EAS program was created. Still Diomede is able to participate in theAir Transportation to Non-eligible Places program, which requires 50% match funding. The State ofAlaska appropriated**$200,000~00** inthe Fiscal Year 2013 budget as grant match funding for Diomede to participate in the program, whichhas been used by only three communities nationally sincethe EAS program was created 34 years ago. Ithas been a challenging problem and a longprocessto find a solutionto have reliable access for the community ofDiomede. Normally the Alaska Department ofTransportation & Public Facilities would not provide specific comments on air carrier selection or routing structure to EAS. But given the fact the State ofAlaska is providing 50% match funding to subsidize this air service, I think itis appropriate that we provide input to the EAS selectionprocess and contractparticulars. You sent an email to my office onAugust 10, 2012 that said in part: One ofthe.proposals that we received was for boat service from Umiaq Services. Upon receiving the boat proposal; we Vllenno the Department's Office ofGeneral Counsel to request a ruling on whether boat service could be subsidized underthe "Essential AIR Service (EAS) program. The short answer is that OGC ruled thatthe EAS statutes do not permit our subsidizing boat service, so that is no longer an option for your consideration.

"GetAlc:ska service and

# . Therefore it is my understanding EAS has crnly one proposal under review, which was submittedby Evergreen Helicopters, Inc. I understand they propose to fly a four-leg itinerary once a week for 44 weeks under the EAS contract: Nome-Diomede, Diomede-Wales, Wales-Diomede, and Diomede-Nome. While I thinkthis creative routing structure maxiri1izes community access given the funding constraints, theproposal assumes an ice runway would be available-for eightweeks during the winter. l.am concerned about the possibility the ice runway mightnot form this year, and I thinkthere needs to be a contingencyplan for that possibility. Indeed Evergreen Helicopter, Inc.'s proposal states "Additional service may be provided with the remaining subsidy f\mding, orifthere were instances in which flight legs were cancelled due to weather." l think this is a good idea as there will surely be times when they will not be able to fly because ofarctic weather conditions. Therefore I suggest the contract specify that ifEvergreen is not able to fly during a particular week for some reason, then Evergreen shouldberequired to f1y the routing laterin the year. That is to say, ifthe ice runway does not form thenEvergreen would fly during that time. Regardless, I suggest that Evergreen be required to fly at least 44 weeks in total. Please note that the funds are from the operating fund in this year's budget and are available fl·om July l, 2012 to June 30, 2013. Given \Ve are now in week eight ofour fiscal year, t1ying at least once a week tor44 weeks perthe Evergreenproposal should not be an issue as there are only 44 weeks leftin the State's fiscal year. This should be enough flights to fly even ifthe ice runway does not form this year. I respectfully urge US DOTto sign the EAS contract for air service at Diomede with Evergreen Helicopters, Inc. as soon as possible because it will significantly'improve access to routine health services.and basic necessities while improving general economic welfare for the community of**~** .,Dioinede,**Alaska~·** Next year'sState grant would be effective'July 1, 2013 to June 30, 2014 assuming the appropriation gets signed next year. Additionally I want to express our support torthe continuation
·· of

### tlie EAS program in Alaskaand the crucial connection 

### it brings to ourremote communities.

Sincerely,


# ..
Steven D. Hatter Deputy Commissioner

- Aviation