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 1 0 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 eleven (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 scheduling 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" airlines and their 

priority/control over terminal gates and baggage handler employees. Building 
• 

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 cancelled. 

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 of these "lates" were in excess of 90 minutes. A number of these late 

arrivals were created by baggage handling 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 

running smoother. 

Based on Merced's overall enplanement history and prior year performance by Great Lakes 

Airlines, we believe our community can easily meet, exceed, and maintain the 1 0-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. Additionally, 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 information. 

Sincerely, 

r.

John 

'- ~ 

M. Bramble 

v "---. ,6\A_ -v~ ~ 

City Manager