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# INTERNATIONAL FALLS
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Mr
. Dennis J. DeVany Chief, Essential Air Service Division Office ofAviation Analysis U. S. Department ofTransportation 1200 NewJersey Avenue SE Washington, D.C. 20590 November 21, 2011 Dear Mr. DeVany, Telephone 218/283-9484 FAX 218/283-3590 

### OFFICE OFMAYOR Shawn Mason

On behalf ofthe City of International Falls and in conjunction with Koochiching County, our airport partner and co-owner, Iwould 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 underthe auspices ofthe federal Essential Air Service program. Before addressing the specifics ofthe proposals, Iwould like to outline what we as a community have determined are our mostfundamental 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 ofcommunity 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 ofour community
. Iwill address them in turn
. • Sufficient summer capacity. • Reliability ofservice
. • Appropriate scheduling. Summer capacity It i swell 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 ofentry, we also serve as agateway for tourists entering and departing from Canada for summer vacation travel.•'

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 ofour local tourist economy, at least up tothe maximum seat allowance provided for underthe EAS program. Withoutthe required number of seats to meet ourtraffic needs, our local resort businesses will suffer and, along with them, the subsidiary businesses that rely on summer tourism fortheir mainstay. We are not asking for more seats than we need. We ask only thatthe United States Department of Transportation requires- or at least allows for-- ourselected carrier to provide the maximum 67 seats permitted, for the period from June through August, which would certainly seem to be afairly good fit for our summer numbers. Nearly halfofour annual enplanements accrue during our shortthree months ofsummer. We cannot afford to lose 10 to 15 percent ofthattotal for lack ofjust afew seats per day. (See enclosure.) 

### Reliability ofservice It is our understanding that, nationwide, most airline cancellations are weather-related. We stand with every other member ofthe traveling public in support ofsafetyfirst and foremost. However, given our geography, we are prone to a significant number ofweather events, particularly in the winter, causing an occasional delay or cancellation. Ifa less than stellar performance record is combined with our already challenging weather environment, we are concerned we will experience a significant leakage oftravelers duringthe 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 afair amount of business in winter months catering to "snowbirds" and other leisure travelers who seek a respite from ourown harsh weather. Everyone here understands aboutweather. But having aflight 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 manyyears, decades actually, building atrusting relationship with our clients on both sides ofthe international border and we fear breaking thattrust through no fault ofour own. Our airportsnow removal operations are excellent, as you might expect given our locale. We will pledge to our commercial service partnerto continue that tradition and to provide impeccably safe and reliable conditions in which to operate, and we can only hope that ourdesignated carrierwill work to match our level ofdedication, in terms oftheir reliability ofequipment and maintenance and sufficiency offleet.•'

Appropriate scheduling As previous documentation will show, Falls International Airport experienced a significant decline in enplanements between summer of2009 and summer of2010. In summer of2009, Delta Airlines announced cessation ofservice to INL, forcing our entry into the EAS program. That fall, Delta reduced our daily flight availability and imposed aflight schedule thatwas highly unfavorable to our clientele, with afirst dailyflight leaving afterthe noon hour and afinal flight leaving from Minneapolis/St. Paul for a return to INL around 2:30p.m., an impossibly small windowfor access to and from our airport. Delta's initial 2009 EAS proposal for INL supposed acontinuation ofthat 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 behalfofthe 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 ofservice 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 simplythat U.S. DOT work with us to ascertain that the reasonable schedule requirement, perthe language ofthe initial legislation, is a specific part ofour 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 ofthe 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 ofserving regional airports similar to our own and that GLA appears able to provide the level ofservice offered in its proposal. We therefore endorse the selection ofGLA 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 ofthe EAS legislation. Private conversations with GLA seem to indicate they plan to overnight an'{ ,.

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. Aflight 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 ofallowances 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 ofa significant reduction ofavailable seats in the summer. It is our understanding that an increase in enplanements is one ofthe 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, notto leave us vulnerable to foreseeable obstacles. Even with the maximum number ofseats in summer, it is quite possible that our enplanements will dip in any event because of public perceptions, right orwrong, thatthere has been a reduction ofthe level ofservice as to aircrafttype 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 ofthe border, to maintain our numbers in the face ofthese challenges. We simply ask that whatever contract ensues does not make ourjob more difficultthan 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, ifthe 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 outliningthose 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 ofquestions provided to them some time ago. The questions address many ofthe 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•'

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 ofAeronautics Peter Makowski, Office of Sen. AI Franken Jerry Fallos, Office ofSen. 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 ofCommerce Paul Nevanen, Koochiching Economic Development Authority Enclosures: MMB/MDAsurvey results Letter from Koochiching Economic Development Authority Chart with daily summer flight patterns