20 July2012 

DOCKET DOT~OST-2012-0069 

The Honorable Ray laHood 

Secretary 

U.S! Department of Transportation 

1200 New Jersey Ave., SE 

Washington, DC 20590~0001 

D.ear Secretary LaHood: 

I 

Box 52 

Ttnakee Spdngs, Alaslm 99841 

Phone 907-7J(J~2l07 

Fmx 907-736-2249 

C/1 

<J1 

U.J 

i'bls letter is ln response to the comments of SeaPort Airlines regarding my communitY's application for small 

Community Air Service Development funds made as a Consortium with the cities of Af1goon and Pelican and the 

unincorporated community of Elfin Cove. I fifld SeaPort's letter to be caprlcious and unnecessary and would normalLy 

not respond to such a dearly self-serving rebuttal but felt compelled to set the record straight on behalf of the 

Consortium and so submit this reply to the information presented in SeaPort's letter. 

SEiJaPort' s letter contains two primary arguments: global dlstr.ifitution system setup is outside me stope of the Sman 

Community Air Sentice Development Grant Programi and a stated concern that any funds awar:Ged ooufd he used to 

compete with Sea.Portvia a separate comptmy not tncluded or partinenU:othe Cbns.ortiutn1s application--Air Excursions. · 

The Consortium Proposal is fully within the Scope of the SmaU Community Air Service Dev'e.,pmentGrant Proaram 

Providing our remote Alaskan communities access to global tb:::ket distribution systems is entirely within the scope of 

marketing as In fact, marketing/is defined by the American Marketing Association as '

1 

••• creating, communicating, 

delivering, and exchanging offerings that have value for ct~stomers. clients, partners, and society at large." Using this 

definition adopted by thousands of prOfe$siona~s throughout the United States, the cons~:>rtiU,m is asking oniy for 

marketing funds·- which the Departmenthastraditionally enthusiastically supported in W tommunitiesfike ours. A.tght ... now, our communities are invisible to much of the world, aswe are not.patticipants.in thecontemporary:portals.through 

which travel is planned in the modern age. As our SCASO applklatltim potnts out, presence In the. Gfobal Distribution 

· Systt:tm is the only effective means.ofmarketing.scheduled air setvice.toourmmmunities and putting us ''on the map." 

SeaPort's letter makes several references to "subsidy" and a "competitive market.# Alaska Seapfanes serves only four 

markets, and it ts, the sole scheduled air carrier rn each ofthem. Further, our consortium is asking for only marketing 

in the traditional sense. The idea of this being a $Ubsfdy is not materially cftffer.ent than other 

marketing being considered a subsidy. 
The cornments by SeaPort aim to stack high several "unknowns" -what is known is that this grant, when consitiered to 

benefit communities, is relatively small and will have measurable and tc;mg·term benefits. i:Vf.ll"' if Alta$ka S~aplanes 

discontinues service to our communities, the three years ofgfobal connectivity and the lo11g-term benefits ofthe direct · 

marketing portion of the grant, enjoyed by the residents and visitors ofour communities woufd have been aw0rthy 

investment; of the SCASD program and fully within its goals. 

Safeguards are Already in Place to Prevent Misuse of Funds 

Finally, th<~ Department should be confident thatthe cities will worktog .. er to carefully remit reimbursement only 

where the grantees are beneficiaries of expenditures. WewouJdhaveno reason to provideanyfundingforfhe benefitof 

the separately authorized and certificated airline Air Excursions. Reason enot,tghaside, the Consortium is fully aware of 

the fact that Afasl<a Seaplanes and Air Excursions have the same owners, and that is where it ends. The airtines are 

certificated separately, managed separately, have separate employees and most ;im~ort:ant--operate separate 

reservation systems. It would be unethical and tnegalforthe consortium~to us~ awarded funds to separately benefit an 

airline not ·operating in our communities. The argument insults our kl'lC>Wiedge ofthetaws.and reg~;~lations oftf;le$0\$0 

and EAS programs, not to mention common sense, and should be thrown out as a consideration ~Y the DOT. Of course, 

the Department will also have ultimate discretion to approve or reject aU invoices. These accountability mechanisms 

should sufficiently lay to rest any legitimate concerns about potential mtsusaoffunds. 

F:inatly, it is absurd that our four smaU communities n:~ust defenct ourselve.s from this attack over alleged subsidlzatiorh 

when the accuser is the most Mavily~subsidized Part 135 operator in the co.._ntry. We are requesting. the~e fiJnds 

because it is in the best interest of long-term sustainability of sch~dulecl air service and. the economit'heCIAth of our 

SeaPort Alrlines1 criticisms are off~pointand pertain to a~ would-be compefltorthat doesri~teven seweour 

market 

t look forward to a continued discussion regarding this innovative apprQ~:~dl to catapulting the visibility of our l~al 

t:iOrrtmunitl,=s to the world. 1 am thankful that the Department considers this reqnest. 

....