May 12,2014
Secretary Anthony Foxx U.S. Department ofTransportation 1200 NewJersey Avenue, SE Washington, D.C. 20590 RE: Docket DOT-OST-2008-0299 Dear Secretary Foxx, CITY COUNCIL Geoff Dale- Mayor Mark Gran- Mayor Pro-Tern Rick Breland- Council Member Doug Cox

- Council Member BettySampson-Council Member CITYCLERK DebraJackson CITYTREASURER

Stacycox

It has come to our attention thatthe Imperial County Airport "IPL" is one ofthirteen airportsthat were notified byTentative Order by the United States Department ofTransportation thatthe community may lose Essential Air Service "EAS" eligibility due to the averages offewerthan ten enplanements per day. While we are not protesting the numbers, we look forward to petitioningforawaiver ofthese standards based on our position thatthese numbers are based on atemporary decline as allowed in the order. IPL is located in the Southeastern cornerofCalifornia. It is bordered by Arizona and Mexico. Even though it is about 114 miles to San Diego, road access tothe nearest large hub airportto Imperial County is made uniquely more challengingthan distance alone dueto congestion, unpredictable border crossings, and road closures due to weather conditions on all roadways leading out of Imperial County. This increases the amountoftime that passengers need totravel to other airports, as well as increases the community's reliance on IPL for access to the international airtransportation networkto support economic growth in the area. IPL has been served by two carriers, United Airlines operated by SkyWest, which ceased service in April of2013, and Seaport Airlines, which began service in May 2013 when the US DOT selected Seaport as the new EAS carrier. Seaport's service replaced flights to LAX with service to large-hub San Diego International Airport "SAN" and Burbank's Bob Hope Airport "BUR", a medium-hub airport North of LAX. Despite the advantage ofhaving access totwo airports, this federally mandated service attracted fewer passengers because it is flown on smaller aircraft, and Seaport did not initially have interline agreements in place to allow passengers totransfer at SAN and BUR to other airlines. In addition, SAN and BUR offer fewer connecting opportunitiesthan LAX, because fewer airlines and routes are served from SAN and BUR. As a result ofthe smaller aircraft operated by Seaport, the numberofdaily seats offered from IPL was approximately halfthe numberoffered by United. IPL consistently generated approximatelytwenty passengers per day in 2009 through 2012. IPL passengertraffic peaked in 2007 when the airport had nearlytwice daily service to LAX and YUMA, Arizona "YUM". United's service with online and interline connecting opportunities at LAX allowed both business and leisure travelers to travel globally and on a larger aircraft, the 30-seat Embraer 120. During

420 SOUTH IMPERIAL AVENUE • IMPERIAL, CA 92251 • TEL (760) 355-4371 • FAX (760) 355-4718 • WWW.CITYOFIMPERIAL.ORG2007, IPL also reached its highest load factor of52%. IPL was hit hard by the weak economy in 2008, 2009 and 2010 with an immediate decline in traffic and load factor. As IPL started to emerge from the recession, airtravel increased to 20.6 in 2012. In 2013, the US DOT selected a new airline, serving new markets and passengertraffic decreased. This temporary decline is because the community must adjusttothe new airservice patterns at IPL, and Seaport needed time to negotiate and interline agreements with otherairlines at BUR and SAN. At this time Seaport is surpassing the required 10 enplanements perday. As such, it is certain thatthe passenger performance below US DOT minimum was atemporary decline related to the entrance ofa new EAS carrier serving new markets from IPL. The City of Imperial and Imperial County are unified in its support ofthe Seaport service and lookforward to petitioning a waiver ofthese standards listed in DOT-OST-2008-0299. Thank you foryour consideration. Should you have any questions, please contact the City of Imperial at (760} 355-4373 oremail mbest@cityofimperial.org.

GeoffDale Mayor City of Imperial

cc. Susan Kurland, Aviation and International Affairs Rebecca Terrazas-Baxter, Office ofCongressman Juan Vargas, CA-51 Kevin Schlemmer, Essential Air Service 

### & Domestic Analysis Division Jamie Jones, David Turch 

### & Associates Marlene Best, City of Imperial