20 July2012

DOCKET**DOT~OST-2012-0069**
The Honorable Ray laHood Secretary U.S! Department ofTransportation 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 ofElfin Cove. Ififld SeaPort's letterto 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 ofthe 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:otheCbns.ortiutn1s

### application--Air

### Excursions. ·
The Consortium Proposal is fully within the Scope ofthe 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 atlarge." 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

### Departmenthastraditionallyenthusiasticallysupported 

### in 

### W tommunitiesfike ours. A.tght



## ... now, our communities are 

### invisible 

### to much 

### ofthe world, aswe are 

### not.patticipants.inthecontemporary: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 andputting

### us ''onthe

### 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 ofthis 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 thatthis grant, when consitiered to benefit communities, is relatively small and will have measurable and tc;mg·term benefits. i:Vf.ll"' 

### ifAlta$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; ofthe 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 

### reasonto 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 ourkl'lC>Wiedge ofthetaws.and**reg~;~lations**oftf;le$0\$0 and 

### EAS programs, not to mention common sense, and should be 

### thrown out as

## aconsideration**~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 thisattack 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 

### Alrlines 1 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. 1am thankful that the Department considers this reqnest.



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