I 

~-"" · ~ __ S_p_~i_n_gf~~J_d=_B_r_a_n_s_o_n_.J ::;i~gnfi:i :i:~::~:~i s;:sl:: _____ L __ NAT I 0 !':'_~_L_A_I_R P 0 R T +-~-4~2_~86~·-~?-~-~-f ~~-s6_s_.o_s_o_I __ _ 

June 29, 2012 

Ms. Aloha Ley 

Associate Director 

Small Community Air Service Development Program 

United States Department of Transportation 

1200 New Jersey Avenue SE 

Washington, DC 20590 

I 

Re: Small Community Air Service Development Program 

Docket# DOT-OST-2012-0069 

Dear Ms. 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 of Springfield, Missouri, owns and operates the Springfield-Branson National Airport 

(SGF), which is classified as a small hub airport by 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 major hubs. 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 it be 

built. We simply raise a question of fairness. 

The private Branson Airport has touted itself from day one as a completely new business model 

that does not want or need federal aviation funding to be successful. They have stated publically 

they want the competitive advantage of not having 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 airport revenue to pay private shareholders, and to subsidize airline service with 

airport revenue, all of which are prohibited under FAA Grant Assurances. However, none of this 

can be readily verified since they are not required to disclose this information as a private airport. 

We feel federal aviation funding should not be 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 market the private Branson Airport. It would be using public 

funds to promote a private for-profit business. 
. ,'" 

Page2 

June 29, 2012 

Ms. Aloha Ley 

If approved, it would set up an unfair playing field where SGF would be severely disadvantaged 

and could jeopardize the significant public investment made to develop SGF into the state-ofthe-art facility that it is today. Thank you for your consideration of these comments. 

Respectfully Submitted, 

Brian C. Weiler, A.A.E. 

Director of Aviation 
Board of Directors: 

Chairman 

PhilipTaldo 

Vice-Chairman 

An Morris 

Secretary 

Virginia i\•locivnik 

Treasurer 

Mike Moss 

Rnymond Burns 

Scon Comislccy 

Dan Douglas 

Stan Green 

Clarklnvin 

l'vlikc Johnson 

Howard Kerr 

Tun McCarley 

Phil Phillips,Jr. 

l'vl. L. Vun Pouckc 

Legal Council 

John Elrod 

Airport Director 

Kelly L. Johnson, A.A. E. 

Asst. Airport Director 

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

Director of Finance 

Terry L. Fmnklin 

Executive Director and CEO 

Scott V.m Laningham 

'\',, Northwest Arkansas 

FLVl/;' 

Ms. Aloha Ley 

Associate Director 

~ RegionaiAirport 

Small Community Air Service Development Program 

United StiJtes Department of Transportation 

1200 New Jersey Avenue SE 

Washington DC 20590 

Re: Small Community Air Service Development Program 

Dear Ms. Ley, 

The purpose of this letter is to bring your attention to an application which bas been submitted to the 

United States Department of Transportation. 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 of air 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 of this Jetter however references a matter of fairness. 

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 of individual owners or shareholders. 

Competition is healthy and we understand the economic impact of air 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 

One Airport Boulevard • Suite 100 • Bentonville, AR 72712 

Phone: 479-205-1000 • Fax: 479-205-1001 

flyxna.com