VICTORIA REGIONAL AIRPORT 

May 26,2015 

609 Foster Field Drive, Suite F Victoria, Texas 77904 

(361) 578-2704 Fax: {361) 576-0948 

Kevin Schlemmer, Chief~ Essential Air Service & Domestic Analysis Division 

EAS Program, U.S. Department ofTransportation 

West Building 

1200 New Jersey Ave. SE 

'Washington D.C. 20590 

RE: ORDER 2015-5-14; Petition for Waiver and Request for Exemption fromA9 

U.S.C. § 41731(a)(1)(B) 

Dear Mr. Schlemmer, 

Victoria Regional Airport has received USDOT ORDER 2015-5-14, Tentative Findings of 

Average Daily Enplanen1ents and Establishment of Waiver Procedures for Victoria, Texas and 

three other communities. The Order states that the Department finds that Victoria, Texas is 

vvithin 175 miles of the nearest mecliuin hub and that throughout Federal tlscal year 2014 has 

averaged 7.8 enplanements per day. We are aware that this is below the required 10 

enplanements per clay for Essential Air Service (EAS) communities who are within 175 miles of 

the nearest medium hub airport. 

Victoria Regional Airport does not contest this data nor the Department's calculations or 

findings. Victoria Regional Airport does hovvever, contest the potential termination of eligibility 

in the EAS program and is seeking a \Vaiver ur1der 49 U.S.C. § 4173l(e). This letter shall serve 

as our petition for waiver and request for exemption fl·om 49 U.S.C. § 4173l(a)(1 )(B). As made 

evident in the data provide below, the Department should certainly agree that the "reason the 

location averages fewer than ten enplanements per day is due to a tempormJ' decline in 

enplanements" - 49 U .S.C. § 41731 (e) is due entirely to the devastating, poor service offered by 

Sun Air Express. 

Based upon US DOT data, 1 Victoria Regional Airport has averaged over 22 enplanements per 

day from 2003 thru 2012.1n June of2012, United Express (operated by Pinnacle Airlines) 

terminated service in Victoria resulting in three months of no air service. ln October of2012, 

Sun Air Express began service. From the very beginning tlu·oughout the entire t\vo years and one 

month of Sun Air's operation in Victoria, we experienced a drastic decline in enplanements due 

to Sun Air's poor performance. As previously documented, the aircraft provided by Sun Air was 

unable to accommodate passenger baggage resulting in many, many of our customers choosing 
to drive to other airports. Aside fl·om the bnggage-related issncs, the reliability of Sun Air was 

also unacceptable. Over the course of their tenure in Victorin, Sun Air cancelled an nvemge of 18 

flights per month due to mnintemmce (not including wenther-related cancellations). This average 

essentially resulted in a cancellation at least every other day or a total of 460 mnintennncc 

cnnccllntions2 over the twodyear period. Note that these figures do not include the additional 

mnintemmce-related delays, which exceeded their cancellation numbers. In the tom years prior to 

Sun Air Express, Victoria Regional Airport averaged over 16 enplanements per day. Two years 

Intel', we lost over 50% of our market. Under EAS or not, there is not n communi!)' in the United 

States whose market could sustain such poor performance with only one available carrier. 

In November of20 14, Victoria Regional Airport entered into the Alternate Essential Air Service 

program and selected Public Clmrters, Inc. as an indirect air carrier to provide passenger service. 

The aircratl supplied by Public Charters through Corporate Flight lvlanagement meet and exceed 

the requirements of our business commlmity and thcit· performance to date has been superb. 

We've not had a single, maintenance-related cancellation to date. Through aggressive marketing 

and reliable service, we're finally starting to get positive feedback from our flying public and 

based upon current passenger data, we project that our enplanements will increase to levels that 

will allow us to increase capacity and ullimately exceed our previous levels ofpasseitger traffic. 

In summary, we are confident that the recent, tempormy decline in enplanements over the past 

two years was a direct result ofthe poor service offered by Sun Air Express. With om new, 

reliable service matched with the flexibility that Alternate Essential Ail· Service provides, our 

market is slowing returning to where it was before. We hope this properly documents our case 

for seeking a waiver under 49 U.S.C. § 41731 (a)( l)(B). Please do not hesitate to contact me at 

(361) 655-0958 and/or at should you need any fmther intbnnation. 

Sincer~--- _ 

~/{_7 r") /~~Y'/' ---==- - { / ______ ._.~~~ ---- Jason Milewski, C.M. 

Managing Director, Victoria Regional Ail1mrt 

Cc: Honorable Judge Ben Zeller, Victoria County 

Victoria County Commissioner's Comt 

Victoria County Airport Commission 

United States Senator John Comyn 

United States Congressmnn Blake Farenthold 

Dale Fowler; Victoria Economic Development Corporation 

Randy Vivian, Victoria Chamber of Commerce 

2 Dally Reports, submitted monthly to Victoria Regional Airport by Sun Air Express