# CITY OF MERCED "Gateway to Yosemite ..

Merced Regional Airport Telephone 2091385-6873 June 3, 2014 Susan 

### L. Kurland Assistant Secretary for Aviation and International Affairs U . S. Department of Transportation 400 Seventh Street, SW Washington, DC 20590 RE : DOT 2006-6-10, DOCKET OST-1998-3521 Fax 209/388-8994

Waiver Request for Essential Air Service (EAS) Program ; Merced , California Dear Assistant Secretary Kurland , Merced Regional Airport respectfully request's an exemption from 49 U . S .C . 

### § 41731(a)(1)(B). Specifically, a "waiver request" .as to why the Department should not terminate EAS eligibility to Merced , California . Based on criteria passed by Congress in the FAA Modernization and Reform Act of 2012 (Public Law No. 112.95) , Merced did not meet the minimum 10- enplanement per day criterion. In the fiscal year referenced , October 1 , 2012 through September 30, 2013, Merced averaged 7.7 enplanements per day. Historically, meeting the 1 0-enplanement criteria has not been an issue for Merced. From 2000 till 2008 (Great Lakes Airlines started service in September 2008) Merced never averaged less than 10 enplanements per year using a number of different carriers . From 2002 till 2008 Merced actually averaged over 24 enplanements per day. In the year prior to the FAA Modernization and Reform Act of 2012 , Great Lakes Airlines averaged over 11 enplanements per day. There are a couple of reasons Merced did not meet the minimum criteria in 2012. In no specific order or priority : 1 . From July 2012 through September 2013, Great Lakes Airlines made e leven (11) scheduling changes , Three (3) of these changes were "departure/arrival" time changes, eight (8) of these changes were either to drop or add flights on different days and times , and one schedule change was to drop Las Vegas as a destination. Las Vegas was a destination our community has utilized since EAS began . Not all of these schedul ing changes were created by Great Lakes Airlines . LAX terminal issues , specifically terminal space and baggage handling requirements , necessitated time and day changes in order to work around "signature" airli nes and their priority/control over term inal gates and baggage handler employees . Bui ld ing

# • customer confidence , loyalty, and satisfaction is severely hampered by numerous scheduling changes . 2. During the year in question (FY 2012) Merced Regional Airport averaged 7 .7 enplanements... .Great Lakes Airlines scheduled 709 departures and 707 arrivals . Of these , sixty (60) departures and sixty-four (64) arrivals were cance lled . Additionally , Eighty-five (85) departures and two hundred three (203) arrivals did not meet the "on-time" criteria (+5 minutes for departures and +16 minutes for arrival) . A

.vast majority ofthese "lates" were in excess of 90 minutes. A number of these late arrivals were created by baggage handli ng and gate change issues at LAX. Regardless, as with reason #1 above , customer confidence , loyalty, and satisfaction suffered greatly. Currently, these LAX issues have settled down and operations are runn i ng smoother. Based on Merced 's overall enplanement h istory and prior year performance by Great Lakes Airli nes, we believe our community can easily meet, exceed , and maintai n the 10-enplanement per day criteria . What Merced experienced in FY2012 is obviously a temporary set-back based on reasons stated above . Past enplanement history and reliable/dependable service has proven this to be the case. Therefore, the City of Merced , sponsor of Merced Regional Airport, respectfully asks not to be dropped from the EAS program . Add itionally, we ask the DOT to expedite a new EAS contract RFP since our current contract expires September 30, 2014. Please contact Ron Elliott, Merced Regional Airport Manager if you have any questions , concerns , or need additional i nformation . Sincerely, 

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John M. Bramble City Manager