# 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 NewJersey Ave. SE 'Washington D.C. 20590



### RE: ORDER2015-5-14; Petition for Waiver andRequest for Exemption fromA9 U.S.C. § 

### 41731(a)(1)(B)

DearMr. Schlemmer,

Victoria Regional Airport has received USDOTORDER 2015-5-14, Tentative Findings of Average Daily Enplanen1ents and Establishment ofWaiverProcedures for Victoria, Texasand three other communities. The Order states that the Department finds that Victoria, Texas is vvithin 175 miles ofthe nearest mecliuin hub and that throughout Federal tlscal year 2014 has averaged 7.8 enplanements perday. 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 Airportdoes hovvever, contest thepotential termination ofeligibility in the EAS program and is seeking a \Vaiver ur1der 49 U.S.C. § 4173l(e). This letter shall serve
as ourpetition for waiver and request for exemption fl·om 49 U.S.C. §4173l(a)(1)(B). Asmade evident in the dataprovide below, the Department should certainly agree that the "reason the location averages fewer than ten enplanementsperday is due to a tempormJ'decline in enplanements"

- 49 U.S.C. 

### §41731(e) is due entirely to the devastating, poorservice offered by Sun AirExpress.
Based upon USDOTdata, 1Victoria 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 ofno air service. ln Octoberof2012, Sun AirExpress began service. From the very beginning tlu·oughout the entire t\vo years and one month ofSun Air's operation in Victoria, we experienced a drastic decline in enplanements due to Sun Air's poor performance. Aspreviously documented, the aircraft provided by Sun Air was unable to accommodate passenger baggage resulting in many, many ofour customers choosingto drive to other airports. Aside fl·om the bnggage-related issncs, the reliability ofSun Air was also unacceptable. Over the course oftheir 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 acancellation at least every otherday or a total of460 mnintennncc cnnccllntions2overthe twodyear period. Note that these figures do not include the additional mnintemmce-related delays, which exceeded theircancellation numbers. In the tom years prior to Sun Air Express, Victoria Regional Airport averaged over 16 enplanements perday. Two years 

### Intel', we lost over 50% ofourmarket. 

### Under EAS ornot, there is 

### not ncommuni!)' in 

### the United States whose market 

### could sustain such poorperformance 

### with only one available 

### carrier.

In November of2014, 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 ofour 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 passengerdata, 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 ofthepoor service offered by Sun AirExpress. With omnew, 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'/'** 

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______**._.~~~**

Jason Milewski, C.M. Managing Director, VictoriaRegional Ail1mrt

Cc: Honorable Judge Ben Zeller, Victoria County Victoria County Commissioner's Comt Victoria County Airport Commission United States SenatorJohn Comyn United States Congressmnn Blake Farenthold Dale Fowler; Victoria Economic Development Corporation Randy Vivian, Victoria ChamberofCommerce

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