## RICHARD A. 

## HENSON FIELD COMMERCIAL & 

## COMMUTER AIRSERVICE 

# IAVIATION MAINTENANCE 

# IAIRSIDE SERVICES
July 18, 2014 Mr. Dennis J. DeVany, Chief EAS & 

### Domestic Analysis Division Office ofAviation Analysis United States Department ofTransportation 1200 New Jersey Avenue, SE Washington, DC 20590 REFERENCE: Docket DOT-OST-2006-25228 SUBJECT: Petition ofHagerstownMaryland for Waiver from the 10-Enplanement Statute DearMr. DeVaney: The Hagerstown Regional Airport onbehalfofHagerstown Marylandherebyrequests a waiver to Order 2014-6-6, issued June 24, 2014, terminating the eligibility ofHagerstown, Maryland under the Essential Air Service (EAS) programbased onrequirements passed byCongress in the FAAModernization and Reform Act of2012 (Public LawNo. 112-95). The Hagerstown Regional Airport requests an exemption from 49 U.S.C. 

### §41731(a) (1) (B) and as such submits the following information to support its petition for waiver: ABILITY TO MEET STANDARDS The Hagerstown Regional Airporthas historically demonstrated its ability to meet orexceed the 10-enplanement requirement. As recently as 2012 before the transition to the current carrier Sun Air, the previous carrier Cape Air with service to Baltimore International Airport had a two year average of 10.5 passengers perday. Priorto Cape Air's service, AirMidwest averaged 18.6 enplanements perdaywith service to Pittsburgh International Airport. The HagerstownRegional Airport is fully confident that the required number ofenplanements canbe met and exceeded ifEssential Air Service is continued with SunAir orother airlines at Hagerstown. OBSTACLES TO MEETINGEAS STANDARDS The Hagerstown Regional Airport would like to citethe following facts that proved to be considerable obstacles to the EAS air carrier SunAir's ability during the 313 day evaluation period to meet the 10-enplanement requirement during its startup ofservice at Hagerstown: ·

18434ShowalterRoad 1Hagerstown, MD 21742 1P: 240.313.2777 1F: 301.791.2590 

### I Hearing Impaired: 7-1-1 

# flyhagerstown.comDennis DeYaney July 18, 2014 Page 2 of3


### • SunAir CEO was averse to adequately marketing the Sun Airproduct. • Sun Air started service withunreliable aircraft that decimated dispatch numbers. • Sun Airhad aircraft not equipped to operate in winterweather conditions. At the start ofEAS service bySunAir, its CEO at the time did not engage in a robust marketing campaignto promote the service. Passenger counts lagged for lack ofpublic awareness ofthe service. This persisted despite the efforts ofthe Hagerstown Regional Airport and the Washington CountyDepartment ofCommunityRelations and CommunityAffairs to assist with the marketing effort. During the startup period, SunAir did not have an adequate maintenance facility established or contractors inplace to respond in a timely manner to aircraft discrepancies that time and again delayed orcancelled departure times
. During the first winter ofits operation, SunAirutilized aircraft that were not equipped with any anti-ice orde-ice capabilities. This resulted in numerous cancellations due to weather. SEQUESTRATIONS NEGATIVE IMPACT ON MEETING EAS STANDARDS Sequestration came into full force as SunAirwas commencing its entryinto the newmarket. This had a significant negative impact on SunAir's startup efforts at Hagerstown. The sequestration imposed the mandatoryreduction ofF AAresources. This forced the agency to redirect its resources, from the activities needed bySun Air to start operations in a timely and efficient manner, to enforcement and monitoring. • SunAirhad a shortage ofroute qualified pilots. • Sun Air had difficulty getting aircraft approved on its Operating Certificate • Sun Air's cold weather operations manual revisions (for ground de-icing and related activities) did not get reviewed and approved for the 2013 winter season. This caused significant flight disruptions and a major loss ofcustomers. Sun Airhad difficulties in securingroute checks and otherrequired FAAcheckrides for its pilot staff. There was one period in excess ofnine months inwhich SunAir did not accomplish one successful check ride. SunAir had difficulty getting aircraft inspectedbythe FAA and placed into service as authorized byits Operating Certificate. This lack ofaircraft for daily schedules and as maintenance spares adverselyimpacted Sun Air's dispatchreliability. There is no doubt that the sequestration was a tremendous burden on Sun Air as it started operations. This fact coupled to the others listed above conspired to make SunAir's EAS debut and subsequent enplanement numbers dismal. REMEDIES TO OBSTACLES TO MEETING EAS STANDARDS The HagerstownRegional Airport would like to describe the remedies that SunAirhas initiated to meet and exceed the 10-enplanement standard: • Sun Air has secured a new CEO and other seniormanagement. • Sun Airhas hired a MarketingManagerto develop the service at Hagerstown. • Sun Airhas established a maintenancebase inLancaster, Pennsylvania
.Dennis DeYaney July 18, 2014 Page 3 of3 

### SunAir's newmanagement team assumed control ofoperations in October 2013. They immediately set about to remedythe issues thathadplagued SunAir's priorperformance. The newmanagement increased qualifiedpilotnumbers, improved the availability ofaircraft for dispatch and worked tirelessly to improve local service at Hagerstown. The dispatch reliability factor rose from 20% at the start ofservice to a high of99% today. Also, the increased emphasis oncustomer service has paid dividends by steadily increasing daily enplanements. Sun Airrecently adjusted their schedule to better align with the United Airlines flight out ofDulles in an effort to increase the enplanements out ofHagerstown. The Marketing Director has been aggressive in promoting the Sun Air service. Hehas been working tirelessly with the local communityto getpassenger levels to increase andhelp business expand inthis region which includes catchment area encompassing four-states. These aggressive tactics have beenrewarded with a growing cadre offrequent flyers from several local companies and small business owners who rely onthe Sun Air Service to meet their travel requirements. These efforts by SunAirto market theirproduct here at Hagerstownhave beenrewarded by a demonstrable growth in enplanements. The number ofenplanements has steadily increased from 

### 3.9 as reported during the startup period to the currentnumber of8 enplanements perday. We anticipate this growth to continue and the 10 enplanementper day statute ofthe EAS ifour petition for waiver is granted. The Hagerstown Regional Airport knows that there is a broad customerbase that will utilize a reliable air service product from Hagerstown to business and travel destinations both domestic and international. The EAS program at Hagerstown is meeting that demand and growing in visibility and popularity. Itwouldbe a tremendous detriment to air commerce in this region ifthe EAS program here at Hagerstown is allowed to go dark.

Airport Director Cc: Kevin Schlemmer, Director ofEAS Attachments 

### Board ofCounty Commissioners ofWashington County, Maryland**.J..,~.,.**



### ohn 

### F. Barr, Vice-President 

# /2JA Cl,__

# c~~ Ruth Anne Callaham, Commissioner

issioner

# •••••••••• tiAGEKSTOWN

- e e e e e e e e WASHINGTON COUN IV e e e. 

# CHAMBER·:· of( ommene
January 24, 2014 Mr. David Hackett, CEO Sun Air International 3201 Griffin Rd. Suite 202 Fort Lauderdale, FL 33312 Dear Mr. Hackett: The Hagerstown-Washington County Chamber of Commerce believes that local passenger air service is a critical transportation link for our membership and that it is important for the continued growth and prosperity ofthe quad-state region. For several decades, local air service has enabled our business community to foster and strengthen relationships around the world. This has allowed employers throughout our region- from Chambersburg, PA to the north, Frederick, MD to the east and Winchester, VA to the south- the ability to better compete and expand into new markets. Such high-profile and well-respected organizations as VOLVO, Manitowoc, Oshkosh, Meritus Health, Macy's, First Data, CSX and Citi, the U.S. National Park Service and the U.S. Army have a continued expectation that our transportation infrastructure can and will support their future business requirements. That infrastructure includes regularly-scheduled service to meet the air travel needs of staff, customers and management. Aviation in Hagerstown has a proud and rich heritage dating back nine decades and including such historically prominent names as Bellanca, Kreider-Reisner, Fairchild Industries and Henson Aviation. Over the years, whether via connections to Pittsburgh, Baltimore or Washington, daily passenger service has been a vital link for our Chamber members to connect to the world marketplace. The Chamber supports Sun Air in its efforts to further strengthen its commitment to providing daily local air service for Hagerstown.Gale 7 LLC 1098 Armada Drive Greencastle. PA 17225 USA Tel:+ 1 717 593 0204 Fax: + 1 717 593 0208
www.gate71/c.com sales@gotelllc.com Todd Willman Sun Air International Galct 7Ud Princes Park. Princesway, TVTE Galeshead, Tyne & Wear. NE 11 ONF, England. Tel: +44 (0) 191 487 8548 Fax: +44 (0) 191 4878547 www.gate7.co.uk soles@gole7.co.uk

65 Jeffries Court Chambersburg, PA 17202 61

h May 2014 Dear Todd, 

# GATE 7 GROUP

It was good to finally meetyou on Thursday May 

### rt, I know we have spoken a few times on the telephone and via email. We have found Sun Air to be a great link between Hagerstown and Dulles Airport both for domestic and International flights. Our CEO is from the UK and he uses Sun Air on all his return flights, he always states how very convenient it is to land in Terminal Bas his British Airways flight is also out ofTerminal B. He therefore does not need to hire a car or have somebody drop him at Dulles and proceed with long security lines. We used tojoke when we first started business in Shady Grove, PA, wouldn't it be great to fly from our local airport in the UK to Hagerstown, with Sun Air we now have that. I also use Sun Air to fly domestically, I now try to select flights from Dulles instead of BWI for the easy link with Sun Air, this actually saves me money as we have no airport parking or car hire to Dulles and in under 40 minutes we are landed and security side in Dulles. ' Hagerstown and Greencastle and over an hour drive from Dulles, Baltimore, Reagan and Harrisburg, add in the fact you need to be at the airport at least an hour and a half before that to,get through security, park a car or return a hire car, you are basically setting off 3 hrs before your flight. I actually decide to drive to some appointments which are less than 8 hours, simply because it can take 6 hours with the commute to one ofthe regional airports. With Sun Air, I can take at least an hour out ofthis scenario. My company and work associates are great supporters of Sun Air, we promote Sun Air to anybody visiting our facility.

Cc Keith Wickham (CEO & President)

Innovative Print SolutionsPlnSBURGH INSTITUTE OF AERONAUTICS P

.0. BoK 10897 • Pittsburgh PA 15236-0897 ( 412) 346-2100 • (412)462-9011 • FAX ( 412)466-051 3 July 17, 2014 To Whom It May Concern: As a partner in the Hagerstown aviation community, the Pittsburgh Institute ofAeronautics (PIA) supports a local air service and believes the continuation ofSun Air in Hagerstown is avital part ofthe Western Maryland community and economy. As Washington County Maryland continues to develop future business opportunities and promotes economic development, affordable airtravel from Hagerstown to Washington Dulles will be critical for future opportunities. The Pittsburgh Institute ofAeronautics-Hagerstown Campus is celebrating its one year anniversary in their newly constructed building located on the grounds ofthe Hagerstown Regional Airport. As you may be aware, PIA's Aviation Maintenance Technology Program leads to testing for the Federal Aviation Administration's (FAA) Airframe and Powerplant (A&P) Certification. In 2013, PIA-Hagerstown placed 94% ofgraduates in the aviation field or related industries. PIA graduates are highly sought after due to theirtransferable skills in technical accuracy in hydraulics, electronics and pneumatics. This educated workforce in the technical fields will be a catalyst to attract future business to this region and daily air passenger service to serve the greater Hagerstown Maryland region will compliment any economic initiative. As our campus grows to serve Maryland, Virginia, West Virginia, Pennsylvania, the daily air passenger service Sun Air provides will support the aviation education and enhance the aviation industry. We look forward to your future support ofgrowing the aviation opportunities in Western Maryland with the continuation ofSun Air atthe Hagerstown Regional Airport. Sincerely,

# 4~<-V" Bernard Adams Campus Director, Hagerstown Pittsburgh Institute ofAeronautics 14516 Pennsylvania Ave. Hagerstown, MD 21742CONVENTION AND VISITORS BUREAU July 17, 2014

To Whom It May Concern: As the official tourism office for Washington County Maryland, we wish to assure the U.S. Department ofTransportation how much we value the service ofSun Air between Dulles International Airport and Hagerstown Municipal Airport. Washington County is home to five National Parks, eight State Parks, 35 county and city parks, and more than 30 museums. We have an award-winningArts & Entertainment District, and as part ofthe Heart ofthe Civil War Heritage Area are home to some ofthe most iconic American Civil War locations in the country and world
-class recreation opportunities. We have competitively priced meeting and conference facilities that offer attendees an excellent choice of local attractions and the convenience of making day-trips to the Washington, DC and Baltimore metro areas. Sun Air's convenient service to a major international airport is considered a significant asset to the tourism industry here. With four round-trip flights on weekdays and two on weekends, business and tourism travelers appreciate reaching their destination via a location that is a hub oftwo major interstate highways; offering easy access to a multitude ofattractions, and our regional residents enjoy the ease oforiginating their air trips from our smaller airport with free parking. The positive economic impact ofthese flights is considered of high value to the CVB and losing the Sun Air service from Hagerstown Municipal Airport is not a future we wish to envision. Sincerely,

Julie M. Rohm Board Chair

16 Public Square Hagerstown, Maryland 21740 301-791- 3 246 fax 301-791-2601


### w w w . mary I an d memories

. comTo Whom It May Concern : I am a contractor for the U.S. Department of Energy in Germantown, MD. Myself, and several other co-workers live in Hagerstown or Waynesboro. We have started to use the Sun Air flights to/from Hagerstown/Dulles as schedules permit for our work travel. #1, it's much more convenient than driving to Dulles (or other DC area airports) #2, it's cheaper for the government than paying for the mileage, parking, etc #3, it's much more relaxing than the drive to a DC area airport

. I and my co-workers intend to continue to utilize this service as often as we can (as I have previously said) as schedules permit. The staff at Hagerstown is courteous and friendly

. We would surely hate see anything happen to this service and strongly urge it's continuance. Sincerely, 

### John 

## c. MiLLs TeLecommunications Security SpeciaList I 

### COMSEC Custodian Advanced Resource**TechnoLogies~** 

### Inc. (ARTI) Contractor to the US Department of Energy AU-1.2; MS:D-315/GTN 1666 Independence Ave. SW Washington DC 26585 361-963-8837 (desk) 361-963-9661 (fax)

"Twenty years from now you wiLL be more disappointed by the things that you didn't do than by the ones you did do. So throw off the bowLines. SaiL away from the safe harbor. Catch the trade winds in your saiLs. ExpLore. Dream. Discover."

-- Mark Twain

## July 16, 2014
To Whom It

## May Concern: We are writing this letter to encourage youto support Sun Air's continuing daily service from Hagerstown, MD to Dulles International Airport ( HRGto lAD). We live in Shepherdstown, WV, 14 miles from Hagerstown and 58 miles from lAD. And 80 miles from BWI. We use HRG's daily service to lAD whenever we fly. The 25 minute flight is much more convenient and cost effective than driving to lAD, which takes 90 minutes each way. Also, we go through security and checkbags at HRG, thereby avoiding the long lines at lAD. We have ample free parking in Hagerstown, orwe simply have a friend drop us off, which takes about 30 minutes round trip. We have found Sun Air to be reliable and affordable, and more and more people from our area have recently come to depend onthis service. Again, we encourage you to continue Sun Air's importantroute round trip from Hagerstown MD to Dulles. Sincerely, Mary C. Bell SandraL. Jenkins 35 Red Blossom Circle Shepherdstown, WV 25443

# From: thelmas@aol.com [thelmas@aol.com] Sent: Friday, July 18, 2014 5:42 AM To: Robin Livingston Subject: Hagerstown HGR service Have utililized Sun Air to visit aging mother and family in nearby areas. Have done this for years and do appreciate the SUNAIR service to HGR. Please continue for passengers. Realize that numbers may be small at times, but outstandingly important to us. Thank you SUNAIR for your service, excellent employees, and continued good will. Sincerely, Thelma Sanborn

Thelmas thelmas@aol.comSUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT "A" Digital and Web Advertising Herald-Mail Media - Hagerstown, MD Web banner, Home Page ofwww.herald-mail.com Placements: August, September, 

### 2013 Late April, May, June, 

### 2014



## ,. - i

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## FLY ABOVE THE BUSYTRAFFIC· 

## SITBACKAND RELAX!**~ ~·**  

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## ~ II'J

# -::AIR

, ; ' 0 ., " ' ( 0
.. A L CARRY-ON ,fARES JUST $25 • f. ')
. 1 : ., 4 C**?S l.Jf.'~:r** **, '~M**  CLICK HERE Go Hot.Topics

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CURRENT CONDITIONS

Comcast xfinity On-Line- southern Franklin County, PA E-Mail Log-In Message Center- 300x250 digital ad with link to www.gosunair.com Placements: Late March, April, May, June, 

### 2014
(FLASH animated3-panel ad, depicts SUNAIR logo, aircraft, specialpricing, Hagerstown RegionalAirport mention and web addressforSUNAIR}SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT"B" Outdoor and Billboard Advertising Kegerreis Inc.- Chambersburg, PA Digital outdoor billboards, 1-81/U.S. 30, also 1-81/PA Route 994 Chambersburg Mall/Chambersburg PA Placements: April, May, June, 2014

Current Display: K-aerreis Panel 0 -997-1 NSUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT "C" Newspaper Print Advertising The Record-Herald -Waynesboro, PA 4x12" print ads, run-of-site web ad, lSK impressions at Yahoo.com and Ontarget.com Placements: September, 2013 May, 2014

# :©~SUN 

# AIR S**~** INTERNATIONAL Fly From Nearby Hagerstown MD Regional Airport FREE Parking until your return!

Convenient flights every day, to Dulles International Fares under $60 each way

- call SUN AIR for details Fly above the busy traffic

- sit back and relaxl Arrive just ONE HOUR prior to your departure time get more done at home, and at work! Sun Air is your closest air connection to anywhere in the world! Book your next flight at (877) 849-4998, or on-line at www.gosunair.com or orbitz.com Questions? Call our local counter at: (301) 733-3020 

### LICK HERE TO BOOK NOW! Or Call 1877J 849::4998



## * Fare special of$25 each way not reflected in the above- these are samples of previous 2013 adMobile Advertising DowntownTaxi! SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT "D"

3 Cabs, a Sun Air rear or driver-side panel on each cab, daily service within Washington County, MD Placements : August, September 2013 April, May, June, 2014SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT "E" Public Events and Community Relations

• Airport Open House at Hagerstown, September 22, 2013 Booth at Open House to meet and greet potential local sir service customers (87 contacts)

• Franklin County (PA) Business Expo, Chambersburg, October 19, 2013 Worked with Allegiant and Airport staff, for annual Chamber Business Expo (25 contacts)Radio Advertising SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT "F"

Local Commercial Spots (:30s) • The Oldies Channels (96.3FM/1400AM/800AM - 3 stations) -Chambersburg PA, Hagerstown, MD Placements: August, September, 2013 March, April, May, 2014

• The Eagle (WWEG FM 106.9FM)
- Frederick, MD (Washington County-centric) Placements: March, April, 2014

• WJEJ Radio (1240AM)
- Hagerstown, MD Placements: April, May, June, 2014 (Morning news sponsorships, etc.)SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT"G" Television Advertising Local Station Advertising WHAG TV-25- Hagerstown, MD Broadcast sponsorship @ 5:00 PM newscast Placement: September, 2103 Countywide Cable System Television Advertising 'The Weather Channel' • Antietam Cable- Washington County, MD (72+ appearances per week) Placements: August, September, 

### 2013 March, April, May, 

### 2014 • Comcast Cable- southern Franklin County, PA (84+ appearance each week) Placements: August, September, 

### 2013 March, April, May, June, 

### 2014 

### HAGERSTOWN

CLIENT NAME: SUN AIR ADDRESS: 3301GRIFFIN ROAD- FT. LAUDERDALE, FL CONTACT: TODD WILLMAN- (717) 860.4011

CRAWL CHART (280 CHARACTERS MAXIMUM)
w H y D R I v E w H E N y l y s u N A I R F R 0 M R E I N H A G E R s T 0 w N H I N G T 0 N D u L l E s 1 0 N 

### - L I N E c A R R y 

### - 0 N l u s F R E E p A R K I N I T c H E A p E R T H A N B 0 0 K y 0 u R T I c K E u N A I R c 0 M w E ' R E F 0 R D A B l E w I N G s T R E 

### - c A L l s u N A I R 7 3 3 3 0 2 0 T 0 D A y I

RUN DATES: 3/12/2014- TFN START: 0 R ' 0 G D T 0 A

FILENAME: CRAWL POSITION#:u c A I G H T T 0 u R $ F A R E M A K R I v I A T y 0 u R A N y T ( 3

STOP: N H w A 2 5 s E s N G G 0 A w H 0 1 F E s p I s F E )SUN AIR SUMMARY- HAGERSTOWN REGIONAL MARKETING EXHIBIT"H" Media Information Releases Hagerstown Herald-Mail, other news outlets within the region April 3, 2014- Announcement of improved operations, better flight reliability, new special HGR Fares

# ~@:**SUN** 

# AIR $ 

## '> INTERNATIONAL MEDIA INFORfMDON April3, 2014 Contact: ToddWillman Regional Marketing Manager (717) 860-4011 twillman@gosunair.com

'It's a New Day, and it's a New Sun,' Notes Sun Air CEO; $25 On-Line Fare Special to and From Dulles Promotes Renewed Focus on Service HAGERSTOWN, MD- Sun Air, the area's only local daily passenger air service operating from Hagerstown's Regional Airport, has announced the availability of a low $25 on-line 'carry on' fare special , for travel between Hagerstown and Washington Dulles International Airport

. No adyance purchase is required

. To take advantage of the $25 fare special between Hagerstown and Dulles, tickets must be purchased on-line at www.gosunair

.com . Pricing is valid for carry-on bags only, and does not apply to passengers heading onward from Dulles with checked-through bags

. After beginning local Sun Air flights to Washington Dulles airport in late 2012, the company faced a number of operational challenges driven in part by the impact of the sequester on government resources, and resulting in a shortage of available pilots and aircraft

. Sun Air introduced a new man21gement team in late 2013, and is achieving operational performance levels that now meet or exceed the major U.S. airlines.

"With Sun Air's success in achieving recent reliability improvements, we are now moving forward with more aggressive marketing designed to promote the local Hagerstown airport, and the exceptional value it offers our customers," said Sun Air Director of Marketing, Todd Willman

. Hi!lgerstown Regional Airport allows travelers to avoid the congestion and long lines of the major airports, while at the same time providing free parking. Boarding and security lines take minutes instead of hours, he noted.