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# ___ June 29, 2012
Ms. AlohaLey Associate Director Small Community Air 

### Service Development Program United States Department ofTransportation 1200New Jersey Avenue SE Washington, DC 20590 I



### Re: Small Community Air Service Development Program Docket# DOT-OST-2012-0069 DearMs. Ley: This letter is to raise objections to an application submitted to the United States Department of Transportation (USDOT) for federal grant funding to support air service development efforts at the private Branson Airport, Branson, Missouri. The City ofSpringfield, Missouri, owns and operates the Springfield-BransonNational Airport (SGF), which is classified as a small hub airportby the Federal Aviation Administration (FAA). SGF has direct service to ten destinations from American, United, Delta, and Allegiant Airlines, including multiple daily flights to four majorhubs. There were 365,698 enplanements in 2011. We have no problem with fair competition as it helps keep air fares in check, increases options to the public, and is good for the region's economic growth. We also have no desire that the private Branson Airport fail even though no federal, state, or local governmental entity asked that itbe built. We simply raise a question offairness. The private Branson Airport has touted itselffrom day one as a completely new business model that does not want orneed federal aviation funding to be successful. They have stated publically they wantthe competitive advantage ofnothaving to follow the same rules and grant conditions all public airports must follow to receive federal aviation funding, known as Grant Assurances. We understand they have used this advantage to enter into agreements guaranteeing exclusive rights, diverting airportrevenue to payprivate shareholders, and to subsidize airline service with airportrevenue, all ofwhich are prohibitedunder FAA Grant Assurances. However, none ofthis can be readily verified since they are notrequired to disclose this information as aprivate airport. We feel federal aviation funding should notbe granted to the Branson/Lakes Area Chamber of Commerce and the Convention and Visitors Bureau, even as public entities, because any grant funds would be used exclusively to marketthe private Branson Airport. It

### would be using public funds to promote a private for-profit business.

### . ,'"


### Page2 June 29, 2012 

## Ms. Aloha Ley

Ifapproved, it would set up anunfairplaying field where SGF would be severely disadvantaged and couldjeopardizethe significantpublic investment made to develop SGF into the state-ofthe-art facility that it is today. Thank 

### you for your consideration ofthese comments. Respectfully Submitted,

Brian C. Weiler, A.A.E. Director ofAviationBoard ofDirectors: Chairman

PhilipTaldo Vice-Chairman

An Morris Secretary

Virginia i\• locivnik Treasurer

Mike Moss Rnymond Burns Scon Comislccy Dan Douglas Stan Green Clarklnvin l'vlikcJohnson Howard Kerr Tun McCarley
Phil Phillips,Jr. l'vl. L. Vun Pouckc LegalCouncil

John Elrod AirportDirector

Kelly L. Johnson, A.A.E.
Asst.Airport Director

Mark H. iVIclllngl!r, A.A.E.
DirectorofFinance

Terry L. Fmnklin Executive Directorand CEO

Scott V.m Laningham '\',, NorthwestArkansas 

# FLVl/;'

Ms. Aloha Ley Associate Director

### ~

### RegionaiAirport

Small CommunityAir Service DevelopmentProgram United StiJtes DepartmentofTransportation 1200 NewJersey Avenue SE Washington DC 20590 Re: Small Community Air Service Development Program DearMs. Ley, The purpose ofthis letter is to bring your attention to 

### an application which bas been submitted to the United States Department ofTransportation. It is a federal grant funding application for air service development for a privately owned and operated airport, the Branson Airport in Branson Missouri (BKG) DOT-OST-2012-0069. We understand the competitive nature of attracting passengers and attaining air service. This is a challenge for any airport. The Northwest Arkansas Regional Airport (XNA) is also seeking funding for an air service development grant for the first time in our history due to the high cost ofair fares and the need for a low cost carrier. We are a small hub airport with several air carriers and non-stop destinations. The purpose ofthis Jetter however references a matter offairness. While 1 understand the grant process is available to public entities and BKG is not directly the applicant, the outcome is the same- public funds being used to support a private enterprise. BKG does not have to follow the same federal regulations and grant assurances that are mandated at public use airports. Private airports grant exclusive agreements that limit competition and they don't have reporting requirements to the public. In short, they can do many things as 

### a private entity that place publicly owned and operated facilities at a competitive business disadvantage. Public use airports don't answer to shareholders and certainly don't share revenues. All revenues are used according to regulation and don't pay dividends or airport generated revenue to subsidies air carriers who are also operating for the profit ofindividual owners or shareholders. Competition is healthy and we understand the economic impact ofair fares to the public. We also understand the considerable federal, state and local investment in XNA's airport. With this said, we respectfully submit that a private business should not benefit from 

### a public funding program which will further damage our ability to compete on a level playing field
.

Alice L. Walton Terminal Building OneAirport Boulevard • Suite 100 • Bentonville, AR 72712 Phone: 479-205-1000 • Fax: 479-205-1001 flyxna.com