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Mr. Dennis J. DeVany 

Chief, Essential Air Service Division 

Office of Aviation Analysis 

U. S. Department of Transportation 

1200 New Jersey Avenue SE 

Washington, D.C. 20590 

November 21, 2011 

Dear Mr. DeVany, 

Telephone 218/283-9484 

FAX 218/283-3590 

OFFICE OF MAYOR 

Shawn Mason 

On behalf of the City of International Falls and in conjunction with Koochiching County, our airport 

partner and co-owner, I would like to take this opportunity to thank you for allowing us to comment on 

the proposals for commercial air service offered for Falls International Airport under the auspices of the 

federal Essential Air Service program. 

Before addressing the specifics of the proposals, I would like to outline what we as a community have 

determined are our most fundamental requirements for air service. Those critical points are listed 

below. We also have worked with the Minnesota Office of Management and Budget/Management 

Analysis and Development Division to complete a survey of community stakeholders and the results are 

included with our submission. Those results confirm and greatly expand upon our discussion below. 

We have identified the following air service needs as critical to the social and economic well-being of our 

community. I will address them in turn. 

• Sufficient summer capacity. 

• Reliability of service. 

• Appropriate scheduling. 

Summer capacity 

It is well known, and we certainly acknowledge, that for travelers coming from outside the region, 

International Falls and the larger Rainy Lake area are primarily a summer destination. As an international 

port of entry, we also serve as a gateway for tourists entering and departing from Canada for summer 

vacation travel. 
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Our records indicate that average daily boardings from Falls International Airport as well as daily 

arrivals, between Memorial Day and Labor Day, equal or often exceed the 67 daily seats allowed for 

subsidization under the EAS program. Delta Airlines has responded to that economic reality by adding a 

third unsubsidized flight during summer months since June 2010 when our EAS agreement with them 

was finalized. 

We believe it is critical that whatever carrier is chosen for service at INL have the capacity to increase 

summer options as needed to accommodate the requirements of our local tourist economy, at least up 

to the maximum seat allowance provided for under the EAS program. Without the required number of 

seats to meet our traffic needs, our local resort businesses will suffer and, along with them, the 

subsidiary businesses that rely on summer tourism for their mainstay. 

We are not asking for more seats than we need. We ask only that the United States Department of 

Transportation requires- or at least allows for-- our selected carrier to provide the maximum 67 seats 

permitted, for the period from June through August, which would certainly seem to be a fairly good fit 

for our summer numbers. Nearly half of our annual enplanements accrue during our short three months 

of summer. We cannot afford to lose 10 to 15 percent of that total for lack of just a few seats per day. 

(See enclosure.) 

Reliability of service 

It is our understanding that, nationwide, most airline cancellations are weather-related. We stand with 

every other member of the traveling public in support of safety first and foremost. However, given our 

geography, we are prone to a significant number of weather events, particularly in the winter, causing 

an occasional delay or cancellation. 

If a less than stellar performance record is combined with our already challenging weather environment, 

we are concerned we will experience a significant leakage of travelers during the winter months. We 

have a robust cold-weather testing operation based at our airport, which draws clients from all over the 

world. Our airport also does a fair amount of business in winter months catering to "snowbirds" and 

other leisure travelers who seek a respite from our own harsh weather. 

Everyone here understands about weather. But having a flight not show up for other reasons means 

that next year people will likely depart from somewhere else. It is too time-consuming and expensive to 

be disappointed in that manner. We have spent many years, decades actually, building a trusting 

relationship with our clients on both sides of the international border and we fear breaking that trust 

through no fault of our own. 

Our airport snow removal operations are excellent, as you might expect given our locale. We will pledge 

to our commercial service partner to continue that tradition and to provide impeccably safe and reliable 

conditions in which to operate, and we can only hope that our designated carrier will work to match our 

level of dedication, in terms of their reliability of equipment and maintenance and sufficiency of fleet. 
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Appropriate scheduling 

As previous documentation will show, Falls International Airport experienced a significant decline in 

enplanements between summer of 2009 and summer of 2010. In summer of 2009, Delta Airlines 

announced cessation of service to INL, forcing our entry into the EAS program. That fall, Delta reduced 

our daily flight availability and imposed a flight schedule that was highly unfavorable to our clientele, 

with a first daily flight leaving after the noon hour and a final flight leaving from Minneapolis/St. Paul for 

a return to INL around 2:30p.m., an impossibly small window for access to and from our airport. 

Delta's initial 2009 EAS proposal for INL supposed a continuation of that same schedule, which had 

caused a 30 percent dip in our enplanement rate almost immediately. The community responded by 

asking U.S. DOT to reject the Delta proposal unless a more reasonable schedule could be agreed upon, 

and U.S. DOT responded favorably on behalf of the community. Since the current EAS contract was 

finalized in June 2010, allowing us a more reasonable schedule with an early morning departure and an 

evening return, our enplanements have continued to climb back toward their previous levels, despite 

the challenging economy. 

We realize and understand that U.S. DOT cannot mandate a particular schedule of service from a carrier 

when it awards an EAS contract. But we know from experience how devastating-- or promising-- a 

schedule can be, and we ask simply that U.S. DOT work with us to ascertain that the reasonable 

schedule requirement, per the language of the initial legislation, is a specific part of our ultimate 

contract. 

Sovereign Air 

As to the proposals that have been tendered for Falls International, it is our understanding that 

Sovereign Air does not have a current operating certificate and therefore is not able at this time to fulfill 

the conditions of the proposal it has put forward for INL. 

While the aircraft size and flight frequency offered would seem to be a good fit for our airport, and the 

financial requirements are not out of line with what is currently being paid, we nevertheless cannot 

recommend that you place us with a carrier not available for service at this time. 

Great Lakes Aviation 

We recognize that Great Lakes Aviation (GLA) has an established history of serving regional airports 

similar to our own and that GLA appears able to provide the level of service offered in its proposal. We 

therefore endorse the selection of GLA as our EAS carrier. 

We do so however with certain requests and caveats in keeping with the points outlined above. We 

would appreciate U.S. DOT support in framing any contract with GLA to include: 

• Assurances that we will have a flight schedule deemed reasonable within the intent of the 

EAS legislation. Private conversations with GLA seem to indicate they plan to overnight an 
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aircraft at INL. Our current EAS contract with Delta stipulates that arrangement. We would like 

to have such a stipulation included in a contract with GLA. 

A flight up and back from the Twin Cities in the evening and another (possibly deadheaded) 

flight up and back in the very early morning seems unnecessarily costly and also opens the door 

for questions around reliability of performance, for weather or whatever other reasons might 

apply. 

• Recognition by U.S. DOT that the maximum 67-seat allowance is appropriate for our airport 

between Memorial Day and Labor Day and consideration of allowances for any additional 

subsidy beyond the 57 seats per day GLA now proposes in writing. 

Community commitment 

There is no question that our enplanements will decline unless the above conditions are implemented, 

simply because of a significant reduction of available seats in the summer. It is our understanding that 

an increase in enplanements is one of the goals of EAS legislation, so it is in keeping with that 

understanding that we ask you to help us maximize our potential as much as possible, or, at the very 

least, not to leave us vulnerable to foreseeable obstacles. 

Even with the maximum number of seats in summer, it is quite possible that our enplanements will dip 

in any event because of public perceptions, right or wrong, that there has been a reduction of the level 

of service as to aircraft type and other "convenience" matters to which people have become 

accustomed. 

For our part, we are engaged in and committed to numerous marketing and planning initiatives and will 

do everything in our power, on both sides of the border, to maintain our numbers in the face of these 

challenges. We simply ask that whatever contract ensues does not make our job more difficult than it 

already is. 

We do believe that a good partnership with our assigned carrier can be productive for all concerned. We 

have the infrastructure, we have the equipment, we have the community partnership and will. Without 

dispute, we are standing by to work in a positive manner with the carrier and, if the carrier is willing to 

work with our community as well, and has the resources to do so, we can all make this venture work. 

We do, however, rely on U.S. DOT to support us in identifying and outlining those few but specific needs 

that will make all the difference and by helping us to assure they are taken into account as we finalize an 

arrangement. 

Lastly, we await responses from GLA to a list of questions provided to them some time ago. The 

questions address many of the concerns raised by our constituents during the survey process conducted 

by the state. We have had verbal assurance that GLA will respond and we respectfully request that 
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those responses are added to the docket whenever they are received, even if not in time for the Nov. 21 

response deadline. 

We thank you as always for your excellent help and guidance. 

City of International Falls, Minnesota 

cc: 

Koochiching County Board of Commissioners 

Chris Roy, MnDOT Office of Aeronautics 

Peter Makowski, Office of Sen. AI Franken 

Jerry Fallos, Office of Sen. Amy Klobuchar 

Alisa Rossini, Office of Rep. Chip Cravaack 

Lori Lyman, Public Affairs, Boise Paper 

Faye Whitbeck, International Falls Chamber of Commerce 

Anthony Mason, Fort Frances, Ontario, Chamber of Commerce 

Paul Nevanen, Koochiching Economic Development Authority 

Enclosures: 

MMB/MDA survey results 

Letter from Koochiching Economic Development Authority 

Chart with daily summer flight patterns